United States Court of Appeals for the Third Circuit

COREY R. KENDIG v. NICHOLAS STOLAR

The Third Circuit affirmed summary judgment for Trooper Nicholas Stolar, holding that while omitting self-defense evidence from a probable cause affidavit can violate the Fourth Amendment, the right was not clearly established at the time of the arrest. Consequently, Trooper Stolar retains qualified immunity despite the court's new rule requiring officers to disclose known facts that conclusively negate the mental state of a charged crime.

UNITED STATES OF AMERICA v. AARON LYONS

The Third Circuit affirmed the dismissal of Aaron Lyons's habeas petition, ruling that his claim based on the Supreme Court's Rehaif decision was procedurally defaulted. The court held that the legal argument regarding knowledge of conviction status was reasonably available when Lyons pleaded guilty, and he failed to demonstrate actual innocence to excuse the default.

In re Whittaker Clark & Daniels Inc.

The United States Court of Appeals for the Third Circuit denied a petition for rehearing en banc in a bankruptcy dispute involving the Official Committee of Talc Claimants. The court granted a panel rehearing to allow for amendments to the majority and concurring opinions without altering the final judgment.

In re WHITTAKER CLARK & DANIELS INC. Debtor WHITTAKER CLARK & DANIELS INC; BRILLIANT NATIONAL SERVICES INC; L.A. TERMINALS INC.; SOCO WEST INC

The Third Circuit denied the petition for rehearing en banc in a bankruptcy appeal involving a settlement approved for talc claimants. The court found no compelling reasons to reconsider the panel's amended opinion, leaving the original judgments approving the reorganization plan in full force.

TZVIA WEXLER v. CHARMAINE HAWKINS

The Third Circuit reversed the judgment against a detective who recommended charges against a civilian, ruling that probable cause existed for the offenses. The court also vacated the punitive damages award against a police officer, reducing it to twelve thousand dollars as constitutionally excessive.

JOHNSON & JOHNSON, a New Jersey corporation; JANSSEN BIOTECH, INC., a Pennsylvania corporation v. SAMSUNG BIOEPIS CO. LTD., a Korean corporation

The Third Circuit affirmed the district court's denial of a preliminary injunction, holding that Janssen failed to demonstrate irreparable harm because monetary damages remain calculable despite market complexities. The court clarified that loss of market share in a breach of contract case does not automatically constitute irreparable injury absent proof that damages are practically impossible to quantify.

Chelsey Gosse v. Transworld Systems Inc

The Third Circuit affirmed a district court ruling granting summary judgment to defendants in a student loan debt collection dispute. The court held that the plaintiff failed to meet the heavy burden required to prove a violation of Pennsylvania's Dragonetti Act.

Briggs v. Southwestern Energy Production Co.

The United States Court of Appeals for the Third Circuit affirmed a summary judgment ruling in favor of an energy company in a dispute over natural gas extraction. The court held that the plaintiffs' claims for trespass and conversion were barred by a valid oil and gas lease ratified by their mother.

UNITED STATES OF AMERICA v. FUQUAN HILL

Y. C. Q., a minor v. CHICHESTER SCHOOL DISTRICT

The Third Circuit held that a Special Education Hearing Officer's order to develop an Individualized Education Program does not constitute an agreement to a new educational placement under the IDEA's stay-put provision. Because no prior IEP was in place, there was no existing placement to maintain, and the student is not entitled to remain in a specific setting pending further proceedings.