3d Circuit Case Commentaries

Claim Preclusion Bars Repackaged § 1983 Theories Arising from the Same Nucleus of Operative Facts

Date: Jan 19, 2026

Claim Preclusion Bars Repackaged § 1983 Theories Arising from the Same Nucleus of Operative Facts Introduction In Dana Smith v. John Decker (consolidated with William Matthews v. John Decker), the...

Claim Preclusion Bars “Repackaged” § 1983 Claims: Added Detail Does Not Create a New Cause of Action

Date: Jan 19, 2026

Claim Preclusion Bars “Repackaged” § 1983 Claims: Added Detail Does Not Create a New Cause of Action I. Introduction In Smith/Matthews v. Decker (Third Circuit, Jan. 16, 2026) (nonprecedential),...

Post-Delligatti: Intentional Injury “By Any Means,” Including Omission, Qualifies as “Use of Physical Force” for Guidelines Crime-of-Violence

Date: Jan 19, 2026

Post-Delligatti: Intentional Injury “By Any Means,” Including Omission, Qualifies as “Use of Physical Force” for Guidelines Crime-of-Violence Case: United States v. Victorious Minter (3d Cir., Jan....

Facially Deficient Anders Briefs: Affirmance Permitted Only After Independent, Whole-Record Review Where the Appeal Is Patently Frivolous

Date: Jan 19, 2026

Facially Deficient Anders Briefs: Affirmance Permitted Only After Independent, Whole-Record Review Where the Appeal Is Patently Frivolous Introduction In United States v. Jarrett Melvin Tarn (3d Cir....

ABIM v. Rushford: Similarity Alone Cannot Establish “Actual Copying” Without Non-Speculative Proof of Access, and Unpreserved Remedies Cannot Revive § 412-Barred Statutory Damages Claims

Date: Jan 18, 2026

ABIM v. Rushford: Similarity Alone Cannot Establish “Actual Copying” Without Non-Speculative Proof of Access, and Unpreserved Remedies Cannot Revive § 412-Barred Statutory Damages Claims I....

Decker v. Pennsylvania DOC: Plaintiffs May Define the “Program” Narrowly Under Title II, and ADA But-For Causation (Not RA Sole-Cause) Can Support Halfway-House Placement Claims

Date: Jan 18, 2026

Decker v. Pennsylvania DOC: Plaintiffs May Define the “Program” Narrowly Under Title II, and ADA But-For Causation (Not RA Sole-Cause) Can Support Halfway-House Placement Claims 1. Introduction In...

INA § 1252(b)(9) Channels Reviewable Legal Questions into Petitions for Review (Not Habeas), Even When Harms Are Immediate

Date: Jan 18, 2026

INA § 1252(b)(9) Channels Reviewable Legal Questions into Petitions for Review (Not Habeas), Even When Harms Are Immediate Case: Mahmoud Khalil v. President, United States of America, et al. (Nos....

Third Circuit Clarifies § 1252(b)(9): “Now-or-Never” Depends on Unreviewable Questions, Not Unremediable Harms

Date: Jan 17, 2026

Third Circuit Clarifies INA § 1252(b)(9): “Now-or-Never” Requires Unreviewable Questions (Not Merely Irreparable Harms) Case: Mahmoud Khalil v. President, United States of America, et al. (Nos....

Younger Abstention and Quasi‑Judicial Immunity Bar Federal Damages-and-Injunction Suits Challenging Ongoing Virgin Islands Attorney Discipline

Date: Jan 17, 2026

Younger Abstention and Quasi‑Judicial Immunity Bar Federal Damages-and-Injunction Suits Challenging Ongoing Virgin Islands Attorney Discipline 1. Introduction In Peter Lynch v. Kathryn Donnelly,...

Rule 404(b) Cooperator-Relationship Evidence and “Common Scheme” Relevant Conduct: United States v. Castillo-Pedraza

Date: Jan 17, 2026

Rule 404(b) Cooperator-Relationship Evidence and “Common Scheme” Relevant Conduct in Drug Cases 1. Introduction In United States v. Diego Castillo-Pedraza (3d Cir. Jan. 14, 2026) (non-precedential),...

Offhand, Non-Targeted Racial Remarks—Without More—Do Not Plead a “Severe or Pervasive” § 1981 Hostile Work Environment; Parallel Title VII Amendments Are Futile

Date: Jan 17, 2026

Offhand, Non-Targeted Racial Remarks—Without More—Do Not Plead a “Severe or Pervasive” § 1981 Hostile Work Environment; Parallel Title VII Amendments Are Futile Introduction In Octavia Poteat v. CP...

PIA § 2102 “Relates To” Requires Substantive Identity of Bid Information, and Rule 11(b)(3) Demands an Element-by-Element Factual Basis

Date: Jan 17, 2026

PIA § 2102 “Relates To” Requires Substantive Identity of Bid Information, and Rule 11(b)(3) Demands an Element-by-Element Factual Basis Case: United States v. Nicole Schuster (3d Cir. Jan. 14, 2026)...

Probable Cause to Seize an Unattended Cellphone Pending a Warrant, and Inevitable Discovery for Pocket Contents During Inventory of Seized Clothing (United States v. Leroy Irvin)

Date: Jan 17, 2026

Probable Cause to Seize an Unattended Cellphone Pending a Warrant, and Inevitable Discovery for Pocket Contents During Inventory of Seized Clothing Case: United States v. Leroy Irvin (3d Cir. Jan....

No Clearly Established Duty to Review Available Photos/Videos Before Seeking an Arrest Warrant (Qualified Immunity) — Dale Morgan v. Centre County

Date: Jan 15, 2026

No Clearly Established Duty to Review Available Photos/Videos Before Seeking an Arrest Warrant (Qualified Immunity) 1. Introduction Dale Morgan v. Centre County, PA is a non-precedential Third...

Defective NTA Is Not Jurisdictional, and Ordinary Emotional/Economic Effects Do Not Meet “Exceptional and Extremely Unusual Hardship”

Date: Jan 14, 2026

Defective NTA Is Not Jurisdictional, and Ordinary Emotional/Economic Effects Do Not Meet “Exceptional and Extremely Unusual Hardship” 1. Introduction In Andres Macias-Chamaidan v. Attorney General...

Corroborated Hearsay and “Good Cause” to Deny Confrontation in Supervised-Release Revocation Hearings

Date: Jan 14, 2026

Corroborated Hearsay and “Good Cause” to Deny Confrontation in Supervised-Release Revocation Hearings 1. Introduction In United States v. Thomas Clay Wade (3d Cir. Jan. 12, 2026) (not precedential),...

Speculative Document-Disclosure Allegations Do Not Create Article III Standing; Jurisdictional Dismissals Must Be Without Prejudice

Date: Jan 12, 2026

Speculative Document-Disclosure Allegations Do Not Create Article III Standing; Jurisdictional Dismissals Must Be Without Prejudice Introduction In Huda Fakhreddine v. University of Pennsylvania (3d...

Affirming Asset-Freeze Preliminary Injunctions to Preserve Collection of a Money Judgment When Successor Liability Is Likely and Dissipation Is Shown

Date: Jan 12, 2026

Affirming Asset-Freeze Preliminary Injunctions to Preserve Collection of a Money Judgment When Successor Liability Is Likely and Dissipation Is Shown Introduction In Rivertown TCI LP v. Optymyze PTE...

ERISA Prudence as a Process-Based Safe Harbor: Robust Consultant-Supported Monitoring Can Defeat Summary Judgment Challenges

Date: Jan 12, 2026

ERISA Prudence as a Process-Based Safe Harbor: Robust Consultant-Supported Monitoring Can Defeat Summary Judgment Challenges Case: Young Cho v. Prudential Insurance Co of America (3d Cir. Jan. 9,...

Third Circuit (Nonprecedential) Clarifies Record-Evidence Demands at Summary Judgment: Isolated Sexualized Remarks and Performance Criticism Do Not Establish a Title VII Hostile Environment or Pretext

Date: Jan 12, 2026

Third Circuit (Nonprecedential) Clarifies Record-Evidence Demands at Summary Judgment: Isolated Sexualized Remarks and Performance Criticism Do Not Establish a Title VII Hostile Environment or...