The case involved a dog rescue organization alleging that state Dog Law officials and local Marcus Hook authorities harassed its members, improperly seized dogs and documents during a 2010 transport, issued citations, and retaliated after the group sued to recover the animals, raising constitutional challenges to the Pennsylvania Dog Law along with federal civil rights and state tort claims. The court granted the defendants' motions to dismiss the Third Amended Complaint in full. It reasoned that Eleventh Amendment immunity barred claims against state defendants, the plaintiff lacked standing for many allegations, the complaint violated pleading requirements, and remaining claims failed to identify sufficient Fourth Amendment or other constitutional violations to support the § 1983 and related causes of action.
Rohm and Haas Company terminated employee Greg Sailor for alleged threatening and harassing comments toward a supervisor, prompting the Union to file a grievance under the collective bargaining agreement that required just cause for discharge. The arbitrator found that the comments were inappropriate but did not constitute threats of violence or justify termination, reducing the penalty to a sixty-day suspension. Rohm and Haas sued to vacate the award while the Union counterclaimed to confirm it, and the district court granted summary judgment to the Union. The court reasoned that the arbitrator's decision drew its essence from the CBA and did not violate well-defined public policies against workplace violence or discrimination, as the remarks were isolated and not shown to create a hostile environment under Title VII or similar laws.
In this bankruptcy appeal, creditor Amrit Lai argued that his pre-petition judgment for unpaid rent created a lien on debtor John Lownes’s mobile home that should have survived the Chapter 7 discharge and not been avoided. The district court affirmed the bankruptcy court’s orders denying Lai’s objections to exemptions and motions for reconsideration. The court reasoned that the mobile home was personal property, as listed in the debtor’s schedules and supported by the record, rather than real property capable of supporting a judicial lien that would pass through bankruptcy; Lai presented no evidence to the contrary. The court also rejected claims that the debtor failed to satisfy credit-counseling requirements or that Lai lacked proper notice, finding the certificates of counseling and education sufficient and the record showing Lai’s participation in the creditors’ meeting.
In this case, Terrance Lewis, convicted in 1999 of second-degree murder and related charges arising from a 1996 robbery and shooting in Philadelphia and sentenced to life imprisonment, sought federal habeas corpus relief under 28 U.S.C. § 2254. New witness testimony and other evidence presented at an evidentiary hearing indicated that Lewis may not have been present or participated in the crime, raising a claim of actual innocence, but the district court approved the magistrate judge's report and recommendation and denied the petition. The court reasoned that AEDPA's deferential standards, combined with the procedural history of Lewis's unsuccessful state post-conviction proceedings, barred relief, and that no clearly established Supreme Court precedent permits habeas relief based solely on actual innocence. A certificate of appealability was granted only on one specified ground and denied on the others.
In United States v. Savage, the government charged defendant Clifton Savage, a convicted felon, with unlawful possession of a firearm under 18 U.S.C. § 922(g)(1) after Philadelphia police recovered a gun from his pocket while responding to a 911 call from a woman reporting that a man was banging on her apartment door with a weapon. Savage moved to suppress both the firearm and his statement admitting to possessing it, claiming that the officers' encounter amounted to an unreasonable search and seizure under the Fourth Amendment and that his statement was obtained in violation of Miranda under the Fifth Amendment. The court denied the motion in full after a hearing, concluding that the officers had reasonable suspicion to stop and frisk Savage based on the reliable, non-anonymous tip and their immediate observations, that the initial questioning in the hallway did not constitute a seizure, and that Miranda did not apply because Savage was not in custody during the brief encounter or, in the alternative, because the public safety exception permitted the questions. The court further noted that the officers' actions were limited and consensual until Savage confirmed he had a gun, at which point they lawfully secured the weapon.
The case involved an eighteen-year-old student with severe hearing loss who had attended Strath Haven High School in the Wallingford Swarthmore School District for several years under an IEP providing specialized support, despite living in a different district. After multiple physical altercations led to suspensions and a proposed forty-five-day placement at an alternative school, the student's mother filed for a temporary restraining order claiming violation of the IDEA's stay-put provision. The court granted the motion and ordered that the student remain at Strath Haven pending administrative proceedings. The reasoning centered on the IDEA's requirement that a child stay in his or her current educational placement during due process disputes, with the district treated as responsible for the placement despite residency issues.