Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. 3rd Circuit Court of Appeals
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The Bureau of Prisons denied the inmate's request to choose his own cellmate. The district court and Third Circuit affirmed, finding the claim without merit.

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A student reported to her aunt, a member of the school board (plaintiff), that she had seen a teacher hugging another student. The investigation ended because the teacher and minor student denied the incident and the plaintiff raised concerns about the reporting student's credibility. More than a year later, a police officer saw the teacher and the minor student in a sexual encounter and the teacher was arrested. A copy of the report on an investigation that followed, containing plaintiff's assertions about her niece's credibility, was leaked to the press during a school board election. The district court dismissed claims under 42 U.S.C. 1983. The Third Circuit affirmed, holding that there is no Fourteenth Amendment right to privacy with respect to the information at issue. Plaintiff may not have intended wide-dissemination of her opinion but she volunteered it to others and it did not concern autonomy and independence in personal decision-making.

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Arrested in 1986 for sex crimes against children and terrorist threats and incarcerated since then, the defendant was granted a new trial by the Pennsylvania Supreme Court in 1992. He was sentenced to 10 to 20 years imprisonment by Northampton County, with credit for time served, and 10 to 20 years by Lehigh County, to be served concurrently. The Lehigh court stated that he would be given "credit ⦠as required by law for all time spent in custody." The Lehigh commitment form effectively granted credit by designating the date of the sentence as 1986. The designation violated state law because credit had already been applied in Northampton County. Recognizing that the defendant was not entitled to double credit, in 2005 the Department of Corrections changed the release date from 2006 to 2011. State courts rejected the defendant's challenges. The federal district court granted a petition for habeas corpus. The Third Circuit reversed and remanded. Rejecting due process claims, the court stated that the state made record-keeping mistake and then corrected it, which is not "conscience-shocking." The defendant's expectation of being released on a particular date did not amount to a constitutionally-protected liberty interest.