3d Circuit Case Commentaries

Accommodations Not Altered Scoring: Clarifying ADA § 309 in Zangara v. NBME

Date: Apr 29, 2025

Accommodations Not Altered Scoring: Clarifying ADA § 309 in Zangara v. NBME 1. Introduction This commentary examines the Third Circuit’s decision in Jason Zangara v. National Board of Medical...

Clarifying Probable Cause and Seizure Elements in §1983 Malicious Prosecution Claims

Date: Apr 29, 2025

Clarifying Probable Cause and Seizure Elements in §1983 Malicious Prosecution Claims Introduction In Theresa Maria Laws v. Borough of Lansdale, the United States Court of Appeals for the Third...

Limits on Casino Liability to Compulsive Gamblers under New Jersey Law

Date: Apr 29, 2025

Limits on Casino Liability to Compulsive Gamblers under New Jersey Law Introduction In Sam Antar v. BetMGM LLC, 3d Cir. No. 24-1364 (Apr. 28, 2025), the Third Circuit addressed for the first time the...

ADA Section 309 Requires Accessible Examination Procedures, Not Score‐ Adjustment Mandates

Date: Apr 29, 2025

ADA Section 309 Requires Accessible Examination Procedures, Not Score‐Adjustment Mandates Introduction Jason Zangara v. National Board of Medical Examiners is a consolidated appeal decided by the...

TransUnion Standard Applied to NVRA: Informational Injury Requires Concrete Downstream Harm

Date: Apr 26, 2025

TransUnion Standard Applied to NVRA: Informational Injury Requires Concrete Downstream Harm Introduction The Public Interest Legal Foundation v. Secretary, Commonwealth of Pennsylvania is a Third...

Mootness of Reversed §7345 Certifications and Tax Court Jurisdictional Boundaries

Date: Apr 26, 2025

Mootness of Reversed §7345 Certifications and Tax Court Jurisdictional Boundaries Introduction Zia Shaikh v. Commissioner of Internal Revenue, No. 25-1215 (3d Cir. Apr. 25, 2025), presents a...

Concrete Downstream Consequences Required for Informational Injury Standing Under NVRA

Date: Apr 26, 2025

Concrete Downstream Consequences Required for Informational Injury Standing Under NVRA Introduction The Third Circuit’s decision in Public Interest Legal Foundation v. Secretary Commonwealth of...

Affirmative Defenses Do Not Undermine Probable Cause in § 3503(b) Defiant Trespass Arrests

Date: Apr 26, 2025

Affirmative Defenses Do Not Undermine Probable Cause in § 3503(b) Defiant Trespass Arrests Introduction This commentary examines the Third Circuit’s decision in Edwin Soto‐Santana v. Stephan Wengen,...

Informational Injury Standing Under the NVRA Requires Concrete Downstream Consequences

Date: Apr 26, 2025

Informational Injury Standing Under the NVRA Requires Concrete Downstream Consequences Introduction In Public Interest Legal Foundation v. Secretary Commonwealth of Pennsylvania, 3d Cir. Nos....

Credibility and Substantial Evidence Standards in LHWCA Disability Determinations

Date: Apr 25, 2025

Credibility and Substantial Evidence Standards in LHWCA Disability Determinations Introduction This commentary examines the Third Circuit’s decision in Global Terminal & Container Services, Inc. v....

Equitable Enforcement of Bankruptcy Fee-Disclosure Requirements and Core Jurisdiction Affirmed in In re Aquilino

Date: Apr 25, 2025

Equitable Enforcement of Bankruptcy Fee-Disclosure Requirements and Core Jurisdiction Affirmed in In re Aquilino Introduction In In re: Louie Joseph Aquilino and Robin Aquilino, Nos. 24-1781, 24-1782...

Waiver of Sixth Amendment Right to Counsel by Repeated Conflict-Driven Conduct

Date: Apr 25, 2025

Waiver of Sixth Amendment Right to Counsel by Repeated Conflict-Driven Conduct Introduction United States v. Omar Morales Colon (3rd Cir. Apr. 24, 2025) addresses the narrow but vital question of...

Waiver of Sixth Amendment Right to Counsel by Conduct: Clarifications from United States v. Omar Colon

Date: Apr 25, 2025

Waiver of Sixth Amendment Right to Counsel by Conduct: Clarifications from United States v. Omar Colon Introduction United States v. Omar Colon, decided on April 24, 2025 by a panel of the Third...

United States v. Williams: Reinforcing the Plain-Feel Doctrine in Protective Pat-Downs

Date: Apr 24, 2025

United States v. Williams: Reinforcing the Plain-Feel Doctrine in Protective Pat-Downs Introduction United States v. Edwin Williams, 3d Cir. No. 23-1494 (Apr. 23, 2025), arises from a traffic stop in...

Specific-Intent Requirement Bars Tort Claim for Refusal to Provide Affidavit of Merit

Date: Apr 24, 2025

Specific-Intent Requirement Bars Tort Claim for Refusal to Provide Affidavit of Merit Introduction Harold R. Berk, a retired attorney, appealed the dismissal of his suit against the Rothman Institute...

Smartphones Are “Computers” Under U.S.S.G. §2G2.2(b)(6): Third Circuit Clarifies Digital-Format Enhancement

Date: Apr 23, 2025

Smartphones Are “Computers” Under U.S.S.G. §2G2.2(b)(6): Third Circuit Clarifies Digital-Format Enhancement Introduction United States v. Randal Wise, 24-2460 (3d Cir. Apr. 22, 2025), presents a...

Attempted Armed Bank Robbery Under 18 U.S.C. §2113(d) as a Predicate Crime of Violence

Date: Apr 22, 2025

Attempted Armed Bank Robbery Under 18 U.S.C. §2113(d) as a Predicate Crime of Violence Introduction In United States v. Ronald Vines, 3rd Cir. No. 23-2843 (Apr. 21, 2025), the Third Circuit addressed...

Mandatory Explanation of Upward Variances Beyond Applicable Guidelines Enhancements

Date: Apr 22, 2025

Mandatory Explanation of Upward Variances Beyond Applicable Guidelines Enhancements Introduction United States v. Timothy Gritman, No. 24-1351 (3d Cir. Apr. 21, 2025), addresses an important...

Excludable Pretrial Motion Delays Under the Speedy Trial Act: United States v. Owens

Date: Apr 19, 2025

Excludable Pretrial Motion Delays Under the Speedy Trial Act: United States v. Owens Introduction United States v. Zachariah Owens (3d Cir. Apr. 18, 2025) addressed whether extended delays between...

Job-Related Medical Documentation Requirements Consistent with Business Necessity Under the ADA

Date: Apr 19, 2025

Job-Related Medical Documentation Requirements Consistent with Business Necessity Under the ADA Introduction This commentary examines the Third Circuit’s unpublished decision in James Chadwick v....