3rd Cir.

United States Court of Appeals for the Third Circuit

Every decision we've summarized from United States Court of Appeals for the Third Circuit.

Apr 3 2026
1:23-cv-02402 Panel Decision

JIM WANG; DEAN WANG; YU BAI v. MASERATI NORTH AMERICA, INC.; JOHN DOES 1-10

The Third Circuit affirmed summary judgment for Maserati because the plaintiffs failed to provide expert testimony proving a vehicle defect caused a garage fire. The court clarified that while expert testimony is not always required for complex instruments, it is necessary when the average juror cannot deduce the cause of failure without technical knowledge.

Civil Insurance Summary Judgment
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Apr 3 2026
25-3196 Panel Decision

BRAHEEM HARTLEY v. DELAWARE COUNTY, PENNSYLVANIA; DELAWARE COUNTY TAX CLAIM BUREAU; JANINE HEINLEIN, Upset Tax Sale Coordinator Delaware County Tax Claim Bureau

The Third Circuit affirmed the dismissal of a pro se homeowner's federal lawsuit challenging a state court tax sale ruling. The court held that the Rooker-Feldman doctrine barred the federal claims because they sought to overturn a state judgment, and res judicata precluded claims that were or could have been litigated in state court.

Civil Other Civil Res Judicata
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Apr 3 2026
24-2199 Panel Decision

UNITED STATES OF AMERICA v. CHRISTOPHER MILLER

The Third Circuit affirmed Christopher Miller's sentence for bank fraud and identity theft, ruling that while the District Court erred in its legal analysis of the Sentencing Guidelines, the mistake was harmless. The appellate court held that applying the correct ambiguity standard still supported the five-participant enhancement based on the aggregate involvement of participants and non-participants.

Criminal Fraud Sentencing Guidelines
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Apr 2 2026
25-2754 Panel Decision

MIRYAM PAOLA SOLER-MARTINEZ; D. P.-S v. ATTORNEY GENERAL UNITED STATES OF AMERICA

The Third Circuit granted the Government's motion for summary action, denying a Colombian national's petition for review of her removal order. The court affirmed the lower agencies' findings that the petitioner failed to exhaust her claims regarding a new particular social group and did not adequately challenge the legal basis for the denial of her asylum applications.

Civil Immigration (Civil) Sixth Amendment - Ineffective Assistance of Counsel
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Apr 2 2026
25-1986 Panel Decision

LILI WAN v. CENTRAL TRANSPORT LLC

The Third Circuit affirmed the denial of Lili Wan's motion for relief from judgment, ruling that pro se litigants must adhere to the same procedural rules as represented parties. The court held that a failure to submit evidentiary material opposing summary judgment cannot be cured post-judgment through claims of excusable neglect or newly discovered evidence.

Civil Summary Judgment Tort / Personal Injury
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Apr 2 2026
25-2718 Panel Decision

JOSHUA ANTHONY JONES v. UNITED STATES OF AMERICA

The Third Circuit summarily affirmed the dismissal of a pro se complaint alleging unconsented human experimentation, holding that sovereign immunity bars claims against the federal government absent an explicit statutory waiver. The court modified the lower court's judgment to dismiss the complaint without prejudice, correcting the procedural error of dismissing for lack of subject matter jurisdiction with prejudice.

Civil Other Civil
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Apr 1 2026
25-1462 Panel Decision

Kason Jamison v. Chrislyn Morgan; Jorge Coons; Nancy Ridgeway; Jannette Murray; Dawn Dougherty

The Third Circuit affirmed the dismissal of Kason Jamison's pro se civil rights complaint, ruling that his allegations were too vague to provide defendants with notice of the claims against them. The court further held that amendment would be futile because the named defendants are protected by absolute judicial immunity or are private actors not subject to liability under 42 U.S.C. § 1983.

Civil Civil Rights - Section 1983
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Apr 1 2026
25-1548 Panel Decision

REUVEN LYAK v. CITY OF HACKENSACK; RAYMOND GUIDETTI

The Third Circuit affirmed the dismissal of a police officer's civil rights claims, holding that internal disagreements over departmental policy do not constitute protected speech under the First Amendment. The court ruled that the plaintiff failed to allege a deprivation of property or liberty interests sufficient to state a procedural due process claim.

Civil Civil Rights - Employment Civil Rights - Section 1983
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Apr 1 2026
25-3392 Panel Decision

RAHEEMAH DONYE SHADIRE WHITMORE v. RAHEEM RYAN WHITMORE; RAHIYA WILLIAMS AND FAMILY; JANAE WILLIAMS; A STRANGE GUY NAMED MACK; FRIENDS/FAMILY OF MALDONADO; TERICKA MARTIN AND RE...

The Third Circuit affirmed the dismissal of a pro se civil rights complaint as frivolous, holding that the appellant's conspiracy allegations regarding hacking and family mistreatment constitute a clearly baseless factual scenario. The court further ruled that the district court properly denied a recusal motion and declined to exercise supplemental jurisdiction over state law claims.

Civil Civil Rights - ADA / Other
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Apr 1 2026
25-1119 Panel Decision

ANTOINE POTEAT v. GERALD LYDON

The Third Circuit affirmed the District Court's dismissal of Antoine Poteat's initial Rule 60(b) motions as moot. The appellate court found no abuse of discretion in treating the original motions as superseded by a subsequently filed amended motion that incorporated their arguments.

Antitrust (Civil) Civil
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