3d Circuit Case Commentaries

United States v. Alan Dorsey — Extending a Completed Traffic Stop Requires Independent Reasonable Suspicion; a Passenger’s Hesitation to Give a Last Name Is Not Enough

Date: Jul 21, 2026

Extending a Completed Traffic Stop Requires Independent Reasonable Suspicion; a Passenger’s Hesitation to Give a Last Name Is Not Enough Introduction In United States v. Alan Dorsey (3d Cir. July 17,...

Receivers May Modify Self-Dealing Lease Terms Despite Attornment Clauses; Conclusory “Lender Breach” Allegations Do Not Vacate Default

Date: Jul 20, 2026

Receivers May Modify Self-Dealing Lease Terms Despite Attornment Clauses; Conclusory “Lender Breach” Allegations Do Not Vacate Default 1. Introduction ICON PSG 1 FL, LLC v. Jenkins Court Realty Co.,...

USSG § 3B1.1(c) in Money-Laundering Sentencing: Oversight of Non-Indicted Participants Supports Role Enhancement

Date: Jul 18, 2026

USSG § 3B1.1(c) in Money-Laundering Sentencing: Oversight of Non-Indicted Participants Supports Role Enhancement Introduction In United States v. Gordon Johnson (3d Cir. July 15, 2026)...

Regulatory-Compliance Clauses Do Not Extinguish “Just Cause”: Third Circuit Reaffirms Extreme Deference to Labor Arbitrators and Bars Judicial Factfinding

Date: Jul 18, 2026

Regulatory-Compliance Clauses Do Not Extinguish “Just Cause”: Third Circuit Reaffirms Extreme Deference to Labor Arbitrators and Bars Judicial Factfinding 1. Introduction In McGuire Memorial v....

Divisibility of N.J. Stat. Ann. § 2C:35-5 by Drug Type and the Noncitizen’s Burden When the Conviction Record Is Inconclusive

Date: Jul 18, 2026

Divisibility of N.J. Stat. Ann. § 2C:35-5 by Drug Type and the Noncitizen’s Burden When the Conviction Record Is Inconclusive 1. Introduction In Faheem Tariq v. Attorney General United States of...

Pleading “Normal Charges” Tied to FAIR Health Percentiles Suffices for ERISA MRC-1 Underpayment Claims; Providers Lack Fiduciary-Duty Standing Absent a Personal Right to the Challenged Plan Assets

Date: Jul 16, 2026

Pleading “Normal Charges” Tied to FAIR Health Percentiles Suffices for ERISA MRC-1 Underpayment Claims; Providers Lack Fiduciary-Duty Standing Absent a Personal Right to the Challenged Plan Assets I....

Direction Alone Is Insufficient to Treat a Membership Organization and Its Local Club as a Single Employer Under Title VII’s Nesbit Parent–Subsidiary Test

Date: Jul 16, 2026

Direction Alone Is Insufficient to Treat a Membership Organization and Its Local Club as a Single Employer Under Title VII’s Nesbit Parent–Subsidiary Test Introduction In Maura Jenkins v. Harrisburg...

Spoliation Sanctions May Presume EEOC Right-to-Sue Notice Receipt Date and Dispose of Time-Barred Title VII Claims

Date: Jul 13, 2026

Spoliation Sanctions May Presume EEOC Right-to-Sue Notice Receipt Date and Dispose of Time-Barred Title VII Claims Case: Jerry Painadath v. Good Shepherd Penn Partners (3d Cir. July 10, 2026)...

DOH Survey Falsifications: Materiality Under 18 U.S.C. § 1035 Need Not Be Tied to an Actual Payment Decision; CMS-Delegate Surveys Qualify as “Federal Matters” Under § 1519; Restitution May Reflect Payments Avoided by Admissions Bans

Date: Jul 11, 2026

DOH Survey Falsifications: Materiality Under 18 U.S.C. § 1035 Need Not Be Tied to an Actual Payment Decision; CMS-Delegate Surveys Qualify as “Federal Matters” Under § 1519; Restitution May Reflect...

Procedural Bars Prevail: Untimely/Number-Barred Reopening and Forfeited NTA Defect Challenges in Removal Proceedings

Date: Jul 11, 2026

Procedural Bars Prevail: Untimely/Number-Barred Reopening and Forfeited NTA Defect Challenges in Removal Proceedings 1. Introduction Lourdes Verenice Hernandez Sorto v. Attorney General United States...

Third Circuit: § 1035 Materiality Does Not Require a Medicare/Medicaid-Payment-Specific Instruction; State Survey Submissions Can Support § 1519 and Restitution Based on Avoided Admissions Bans

Date: Jul 11, 2026

Third Circuit: § 1035 Materiality Does Not Require a Medicare/Medicaid-Payment-Specific Instruction; State Survey Submissions Can Support § 1519 and Restitution Based on Avoided Admissions Bans Case:...

Defamation Liability for “Misquote/Scientific Invalidity” Accusations and Retaliation Protection for Opposing Allegedly Unlawful Race Preferences in Academic Medicine

Date: Jul 11, 2026

Defamation Liability for “Misquote/Scientific Invalidity” Accusations and Retaliation Protection for Opposing Allegedly Unlawful Race Preferences in Academic Medicine Norman Wang v. University of...

Cancellation Hardship Review: Substantial Evidence (Not “Hard-Look” Reasoned Decisionmaking) and Permissible Predictive Findings

Date: Jul 9, 2026

Cancellation Hardship Review: Substantial Evidence (Not “Hard-Look” Reasoned Decisionmaking) and Permissible Predictive Findings Case: Armondo Morales v. Attorney General United States of America (3d...

Anders Withdrawal Granted Where Rule 11 Plea Colloquy and Within-Guidelines Sentence Reveal No Nonfrivolous Appellate Issues

Date: Jul 9, 2026

Anders Withdrawal Granted Where Rule 11 Plea Colloquy and Within-Guidelines Sentence Reveal No Nonfrivolous Appellate Issues 1. Introduction In United States v. Luis Gomez (3d Cir. July 6, 2026)...

Third Circuit: CAT Deferral Requires Individualized Proof of Likely Torture—Arrest and “Ill-Treatment” Evidence Alone Is Insufficient

Date: Jul 9, 2026

Third Circuit: CAT Deferral Requires Individualized Proof of Likely Torture—Arrest and “Ill-Treatment” Evidence Alone Is Insufficient I. Introduction In Javokhir Attoev v. Attorney General United...

Eliminated-Position Discrimination Claims: “Replacement” Alone Does Not Create an Inference, and Retaliation Requires More Than Timing at Pretext

Date: Jul 9, 2026

Eliminated-Position Discrimination Claims: “Replacement” Alone Does Not Create an Inference, and Retaliation Requires More Than Timing at Pretext 1. Introduction In Robert Lynn v. Bank of New York...

Evidentiary Hearing on Suppression Requires a Concrete Factual Dispute—Failure to Contest Marijuana-Odor Probable Cause Defeats the Request

Date: Jul 9, 2026

Evidentiary Hearing on Suppression Requires a Concrete Factual Dispute—Failure to Contest Marijuana-Odor Probable Cause Defeats the Request Case: United States v. Clarence Gaffney (3d Cir. July 6,...

Third Circuit: A Suppression Hearing Requires a Concrete Factual Dispute, and Sentencing Error Requires “Actual Reliance” on Unreliable Allegations

Date: Jul 9, 2026

Third Circuit: A Suppression Hearing Requires a Concrete Factual Dispute, and Sentencing Error Requires “Actual Reliance” on Unreliable Allegations Introduction In United States v. Clarence Gaffney...

Ineffective Assistance Requires Outcome Prejudice Despite Defective Reasonable-Doubt Instructions; Recusal Claims Demand a Concrete Basis and Likely Effect

Date: Jul 4, 2026

Ineffective Assistance Requires Outcome Prejudice Despite Defective Reasonable-Doubt Instructions; Recusal Claims Demand a Concrete Basis and Likely Effect Case: Daniel Lewis v. Superintendent...

“Manager or Supervisor” Under U.S.S.G. § 3B1.1(c) Means Oversight—And Application Note 4 Cannot Supply the Rule Absent Genuine Ambiguity

Date: Jul 4, 2026

“Manager or Supervisor” Under U.S.S.G. § 3B1.1(c) Means Oversight—And Application Note 4 Cannot Supply the Rule Absent Genuine Ambiguity Case: United States v. Timothy Riddy (3d Cir. July 1, 2026)...