Villanova University School of Law: Digital Repository

USDC for the Eastern District of Pennsylvani

USA v. Carl Rose

2025 Decisions 
Opinions of the United 
States Court of Appeals 
for the Third Circuit 
8-22-2025 
Jenn-Ching Luo v. Owen J Roberts School District 
Follow this and additional works at: https://digitalcommons.law.villanova.edu/thirdcircuit_2025 
Recommended Citation 
"Jenn-Ching Luo v. Owen J Roberts School District" (2025). 2025 Decisions. 696. 
https://digitalcommons.law.villanova.edu/thirdcircuit_2025/696 
This August is brought to you for free and open access by the Opinions of the United States Court of Appeals for 
the Third Circuit at Villanova University Charles Widger School of Law Digital Repository. It has been accepted for 
inclusion in 2025 Decisions by an authorized administrator of Villanova University Charles Widger School of Law 
Digital Repository. For more information, please contact reference@law.villanova.edu. 
         NOT PRECEDENTIAL 
 
UNITED STATES COURT OF APPEALS 
FOR THE THIRD CIRCUIT 
___________ 
 
No. 24-3048 
___________ 
 
JENN-CHING LUO, 
   Appellant 
 
v. 
 
OWEN J. ROBERTS SCHOOL DISTRICT;  
SHARON W. MONTANYE; SWEET STEVENS KATZ WILLIAMS LLP;  
   JAMES GERL; PENNSYLVANIA DEPARTMENT OF EDUCATION 
____________________________________ 
 
On Appeal from the United States District Court 
for the Eastern District of Pennsylvania 
(D.C. Civil Action No. 2:21-cv-01098) 
District Judge:  Honorable Harvey Bartle, III 
____________________________________ 
 
Submitted Pursuant to Third Circuit LAR 34.1(a) 
July 24, 2025 
 
Before:  SHWARTZ, MONTGOMERY-REEVES, and SCIRICA, Circuit Judges 
 
(Opinion filed: August 22, 2025) 
 
___________ 
 
OPINION* 
___________ 
 
 
PER CURIAM 
 
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not 
constitute binding precedent. 
2 
 
Appellant Jenn-Ching Luo appeals from orders of the District Court dismissing his 
actions brought pursuant to the Individuals with Disabilities in Education Act (IDEA), 20 
U.S.C. § 1400, et seq., and his related claims.  For the following reasons, we will affirm 
the District Court’s judgment.  
Luo is the parent of B.L., a former special needs student in the Owen J. Roberts 
School District.  In March 2021, Luo filed a complaint in the District Court alleging that 
he filed two administrative due process complaints under IDEA which were denied by 
Hearing Officer James Gerl.  Luo sought the District Court’s review of Gerl’s decisions 
pursuant to the IDEA.  See 20 U.S.C. § 1415(i)(2) (providing a party aggrieved by a 
hearing officer’s decision under the IDEA the right to bring a civil action in a district 
court).  The complaint also included claims for, inter alia, denial of Luo’s due process 
and “liberty” rights pursuant to 42 U.S.C. § 1983.  In addition to Gerl, it named as 
defendants the School District; its counsel during the administrative hearings, Sharon 
Montanye, and her law firm, Sweet Stevens Katz Williams LLP (collectively the attorney 
defendants); and the Pennsylvania Department of Education (PDE). 
In May 2021, the District Court consolidated the matter (Luo VI), for 
administrative purposes only, with four other matters (Luo I, Luo II, Luo IV, and Luo V) 
in which Luo had filed complaints against the School District and various defendants.    
We twice dismissed appeals from orders of the District Court purporting to dismiss all of 
the claims in Luo VI pursuant to Federal Rule of Civil Procedure 12(b)(6); both times, we 
determined that the § 1415(i)(2) actions remained outstanding, and, therefore, that we 
3 
 
lacked appellate jurisdiction.  See Luo v. Owen J. Roberts Sch. Dist., No. 22-1635, 2023 
WL 5600965 (3d Cir. Aug. 30, 2023); Luo v. Owen J. Roberts Sch. Dist., C.A. No. 24-
1031, June 26, 2024 Order.  
After the second remand, the District Court entered an order granting the PDE’s 
motion to dismiss the § 1415(i)(2) “appeals,”1 dismissing “all claims” in Luo VI, and 
denying reconsideration of an order denying Luo’s “motion for entry of default.”  ECF 
No. 54.  Luo appealed. 
We have jurisdiction pursuant to 28 U.S.C. § 1291.  We review de novo the 
District Court’s dismissal of Luo’s claims under Federal Rule of Civil Procedure 
12(b)(6).  See Castleberry v. STI Grp., 863 F.3d 259, 262-63 (3d Cir. 2017).  To survive 
a motion to dismiss, a complaint must allege facts sufficient to “state a claim to relief that 
is plausible on its face.”  Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007).  We 
construe Luo’s pro se pleadings liberally.  See Erickson v. Pardus, 551 U.S. 89, 94 (2007) 
(per curiam).  
IDEA Proceedings 
Luo filed his administrative due process complaints with the Office of Dispute 
Resolution (ODR) challenging the lawfulness of a Notice of Recommended Educational 
Placement (NOREP) provided by the School District.  A NOREP is used to provide a 
 
1 Although the District Court refers to the § 1412(i)(2) “claims” as “appeals,” a 
proceeding under the statute “is properly characterized as an original ‘civil action,’ not an 
‘appeal.’”  Jonathan H. v. The Souderton Area Sch. Dist., 562 F.3d 527, 529 (3d Cir. 
2009).  We refer to the “§ 1415(i)(2) actions” to distinguish them from the other claims.  
4 
 
parent with notice of any potential changes to a student’s Individualized Education Plan 
(IEP).  Luo claimed that the NOREP form violated his “liberty right” because it indicates 
that the action or recommendation will be implemented unless the parent requests “Due 
Process or Mediation through the Office for Dispute Resolution.”  ECF No. 1 at 4.  
Specifically, he argued that the process outlined in the NOREP violates his “right to 
decline to give a consent” by requiring him, as the parent, to take action to prevent 
implementation of changes to the IEP.  Id. at 4-5. 
The School District filed a motion to dismiss the first complaint, arguing that 
Hearing Officer Gerl lacked the authority to rule on the due process complaint.  Gerl 
granted the motion.  He first noted that his authority was limited to remedying “violations 
involving issues of evaluation, identification, placement or provision of [a Free 
Appropriate Public Education (FAPE)].”  12/23/20 Gerl Decision at 3-4.  Gerl 
determined that Luo’s claim regarding the NOREP did not state an actionable IDEA 
violation, and, thus, that he lacked the authority to rule on the complaint.  Luo filed 
another due process complaint, which Gerl determined was “substantially identical” to 
the prior complaint.  1/15/21 Gerl Decision at 3.  Gerl therefore granted the School 
District’s motion to dismiss the second complaint as res judicata.  Id. at 26.  Luo sought 
review of Gerl’s decision orders pursuant to § 1415(i)(2). 
§ 1415(i)(2) Claims 
We first reject Luo’s argument that the District Court erred in failing to enter 
default judgment against the School District and the PDE on the § 1415(i)(2) actions or to 
5 
 
impose sanctions.  A default judgment is warranted where a party “failed to plead or 
otherwise defend” the claims against it.  See Fed. R. Civ. P. 55(a).  Luo incorrectly 
claims that the time to answer the complaint expired 14 days after the District Court first 
dismissed the complaint against both defendants by order entered March 21, 2022.  See 
Fed. R. Civ. P. 12(a)(4) (providing that, if a defendant files a motion to dismiss pursuant 
to Rule 12(b)(6), the defendant must serve an answer within 14 days after the Court 
denies the motion to dismiss).  Luo timely appealed from that order, and, after we 
remanded for consideration of the outstanding § 1415(i)(2) actions, the School District 
“otherwise defend[ed]” the actions by filing a motion to dismiss, which was granted by 
the District Court.  See id.; see also Ashby v. McKenna, 331 F.3d 1148, 1151-52 (10th 
Cir. 2003) (discussing the interplay between Rule 55 and Rule 12(a)(4), and recognizing 
that a defendant has no obligation to answer while a motion to dismiss is pending).  And 
likely because it was unclear whether the parties were required to defend the § 1415(i)(2) 
actions,2 the PDE did not file a motion to dismiss until the District Court directed it to 
address the claims.  Under the circumstances, the District Court did not abuse its 
 
2  The complaint sought “[r]eview” of HO Gerl’s decision, and separately pleaded 
“[c]laim[s]” against the various defendants.  In its initial motion to dismiss, the School 
District did not defend HO Gerl’s decision, stating that “Claim 11” was the only claim 
against it.  ECF No. 11-1 at 2.  Gerl’s decisions were captioned “B.L., Student by 
Parents, v. Owen J. Roberts School District.”  After we remanded the matter a second 
time, the District Court noted that it was acting “in the interest of justice” in giving the 
PDE the opportunity to file a motion to dismiss “what appears to be an IDEA claim 
against it.”  On appeal, the PDE argues, as it did in the District Court, that it was not a 
proper party to those claims.  We need not decide that issue because, as discussed below, 
Gerl properly dismissed Luo’s due process complaint.   
6 
 
discretion in deeming the motions to dismiss as timely filed, and determining that there 
was no basis for default judgment against either defendant.  See generally In re Fine 
Paper Antitrust Litig., 685 F.2d 810, 817 (3d Cir. 1982) (noting that “matters of docket 
control . . . are committed to the sound discretion of the district court”); see also Jorden v. 
Nat’l Guard Bureau, 877 F.2d 245, 250-51 (3d Cir. 1989) (noting the standard of review).   
The District Court dismissed Luo’s § 1415(i)(2) actions on alternative grounds.  
First, it agreed with defendants that the actions were moot because B.L. had turned 21.  
See Ferren C. v. Sch. Dist. of Phila., 612 F.3d 712, 717 (3d Cir. 2010) (stating that “a 
school district’s obligations to provide and a student’s right to receive a [FAPE] both 
terminate when the child reaches the age of twenty one”); see also 22 Pa. A.D.C. § 
12.1(a) (providing that persons “between the ages of 6 and 21 years” are entitled to a 
FAPE in the Commonwealth).  Luo does not meaningfully challenge this determination, 
nor would such a challenge succeed.   
As the District Court recognized, “an individual over [21] is still eligible for 
compensatory education for a school district’s failure to provide a FAPE prior to the 
student turning [21].”  Id. at 718.  But, as the hearing officer concluded, Luo’s due 
process complaint did not state an actionable claim for the denial of a FAPE.  See D.S. v. 
Bayonne Bd. of Educ., 602 F.3d 553, 565 (3d Cir. 2010) (recognizing that a procedural 
violation will constitute the denial of a FAPE only “if it results in a loss of educational 
opportunity for the student, seriously deprives parents of their participation rights, or 
causes a deprivation of educational benefits”).  In particular, Luo did not allege how the 
7 
 
NOREP denied him the right to meaningfully participate in B.L.’s education.3  
Accordingly, the District Court properly dismissed the § 1415(i)(2) actions as moot.  See 
American Bird Conservancy v. Kempthorne, 559 F,3d 184, 188 (3d Cir. 2009) 
(addressing the threshold matter of mootness because it implicates jurisdiction).   
The PDE & Gerl’s Immunity 
We agree with the District Court that both the PDE and Gerl are immune from 
Luo’s other claims.  First, as an arm of the state, the PDE is generally immune from suit 
in federal court under the Eleventh Amendment.  See Fitchik v. N.J. Transit Rail 
Operations, Inc., 873 F.2d 655, 658 (3d Cir. 1989) (noting that a state agency or 
department is an “arm of the state” when a judgment against it “would have had 
essentially the same practical consequences as a judgment against the State itself”).  Its 
immunity extends both to state law claims, see Pennhurst State Sch. & Hosp. v. 
Halderman, 465 U.S. 89, 106 (1984), and § 1983 claims, see Downey v. Pa. Dep’t of 
 
3 Because the due process complaint notices failed to assert the denial of a FAPE, they 
were insufficient under 20 U.S.C. § 1415(b)(7)(A)(ii)(III) (providing that a due process 
complaint notice must include “a description of the nature of the problem of the child 
relating to [a] proposed initiation or change [to an IEP], including facts relating to such 
problem”); see also 34 C.F.R. § 300.508 (providing the same where the due process 
complaint lacks that information).  Pursuant to 20 U.S.C. § 1415(c)(2)(A), the School 
District filed the motion to dismiss the complaint notice, arguing that it did not relate to 
B.L.’s educational program or placement, and thereby notifying HO Gerl that it was 
deficient under § 1415(b)(7)(A)(ii)(III).  See also 24 C.F.R. § 300.510(b)(4) 
(demonstrating that the IDEA contemplates the filing of a motion to dismiss).  Therefore, 
Luo’s argument that he was wrongfully deprived a hearing by an “[un]warranted” motion 
to dismiss (“Point 1”) is meritless.  Appellant’s Br. at 9-10. 
 
8 
 
Corr., 968 F.3d 299, 310 (3d Cir. 2020) (noting that Pennsylvania has not waived the 
immunity defense and Congress has not abrogated Eleventh Amendment immunity under 
§ 1983).  Although the PDE is not entitled to immunity from claims brought pursuant to 
the IDEA, Luo’s IDEA-based claims were grounded in § 1983.4   
Next, Gerl was entitled to absolute immunity from suit because he was acting in a 
quasi-judicial capacity as a hearing officer when he presided over the administrative 
proceedings.  See ECF No. 24 at 18-19; see also Dotzel v. Ashbridge, 438 F.3d 320, 325 
(3d Cir. 2006) (recognizing, in a § 1983 action, that a public official whose “role is 
‘functionally comparable to that of a judge’” enjoys “absolute immunity from suit”); see 
also Petition of Dwyer, 406 A.2d 1355, 1359 (Pa. 1979) (recognizing the same in a state 
lawsuit).  As previously discussed, the IDEA provides for motions to dismiss.  Gerl is 
similarly immune from his actions in sanctioning Luo for his abusive behavior during the 
administrative proceedings.  See Stump v. Sparkman, 435 U.S. 349, 256-57 (1978) 
(recognizing that a judicial officer is immune from actions taken “in error, [  ] done 
maliciously, or [  ] in excess of his authority,” and is “subject to liability only when he 
has acted in the ‘clear absence of all jurisdiction’”).  Accordingly, because the District 
 
4 Luo mistakenly relies on M.A. ex rel. E.S v. State-Operated School District of City of 
Newark, 344 F.3d 335 (3d Cir. 2003), to support his argument that the PDE is not 
immune to his § 1983 claims.  The § 1983 claims in that case were for IDEA violations, 
see M.A. ex rel. E.S., 344 F.3d at 338; but we have subsequently recognized that § 1983 
is not available to remedy IDEA violations, see A.W. v. Jersey City Pub. Sch., 486 F.3d 
791, 803 (3d Cir. 2007) (en banc).  
9 
 
Court lacked jurisdiction over the claims against Gerl and the PDE, it properly dismissed 
them. 
State Law Claims 
Luo pleaded negligence claims against the attorney defendants, and common law 
abuse of process and conspiracy claims against Montanye.  The claims stemmed from the 
administrative proceedings, particularly the motions to dismiss.  As Luo acknowledges 
on appeal, an ordinary negligence claim, like a malpractice action, requires the plaintiff to 
establish that the defendant owed a duty to the plaintiff which was breached.  Merlini ex 
rel. Merlini v. Gallitzin Water Auth., 934 A.2d 100, 104 (2007).  Luo did not allege 
sufficient facts to support his claim that Montanye, as the School District’s attorney, or 
her law firm, owed him a duty, including, as he presses on appeal, a “social duty of care.” 
Cf. Althaus v. Cohen, 756 A.2d 1166, 1168-69 (Pa. 2000).   Nor did he sufficiently plead 
a common law abuse of process claim.  To do so, Luo had to allege that Montanye used a 
legal process against him “primarily to accomplish a purpose for which the process was 
not designed,” causing him harm.  Lerner v. Lerner, 954 A.2d 1229, 1238 (Pa. Super. Ct. 
2008).  Luo alleged only that she “perver[ted]” the process by the filing the motion to 
dismiss in the first hearing.  ECF No. 1 at 18.  Similarly, because the motion to dismiss 
was not “unlawful,” Luo could not state a claim for relief for civil conspiracy.  Goldstein 
v. Phillip Morris, Inc., 854 A.2d 585, 590 (Pa. Super. Ct. 2004) (noting that to state a 
civil conspiracy claim a plaintiff must allege that “two or more persons acted with a 
10 
 
common purpose to do an unlawful act or to do a lawful act by unlawful means or for an 
unlawful purpose”).   
§ 1983 Claims 
We can quickly dispense with Luo’s remaining § 1983 claims.  “[A] plaintiff 
seeking to hold an individual liable under § 1983 must establish that [they were] deprived 
of a federal constitutional or statutory right by a state actor.”  Kach v. Hose, 589 F.3d 
626, 646 (3d Cir. 2009).  The attorney defendants are not liable as state actors for 
performing their functions as attorneys for the School District.  See Angelico v. Lehigh 
Valley Hosp., Inc., 184 F.3d 268, 277 (3d Cir.1999) (holding that “[a]ttorneys performing 
their traditional functions will not be considered state actors solely on the basis of their 
position as officers of the court”).  And the District Court properly concluded that the 
claim against the School District for violation of a “liberty right” fails to state a claim for 
relief.  Luo alleged that his “right to direct his child’s education” was violated by the 
NOREP.  The NOREP merely requires a parent to indicate their agreement or 
disagreement with proposed changes, and, in the latter case, provides an opportunity to 
request a due process hearing or mediation.5  In this regard, the NOREP neither “shocks 
the conscience,” as required to adequately plead a substantive due process claim, see 
 
5 We take judicial notice that, since before 2012, when Luo claims he first confronted the 
“confusing NOREP,” Appellant’s Br. at 2, the NOREP has informed parents of their right 
to a due process hearing or mediation, which they can request on the form.  See, e.g., 
https://www.pattan.net/assets/PaTTAN/de/de805b00-70f0-4d54-90d1-4822158379fb.pdf 
   
11 
 
Miller v. City of Philadelphia, 174 F.3d 368, 374-75 (3d Cir. 1999), nor deprives a parent 
of procedural due process, see  In re Energy Future Holdings Corp., 949 F.3d 806, 822 
(3d Cir. 2020).  
In sum, the District Court properly dismissed the § 1415(a)(i) actions as moot and 
the other claims for failing to state a claim for relief.  We agree that amendment of the 
complaint would be futile.  See Jablonski v. Pan Am. World Airways, Inc., 863 F.2d 289, 
292 (3d Cir. 1988).  Accordingly, we will affirm the District Court’s judgment.  


Jenn-Ching Luo v. Owen J Roberts School District

USDC for the Middle District of Pennsylvani

NRA Group LLC v. Nicole Durenleau

Abdulmalik Abdulla v. Attorney General United States

USA v. Marquis Smalls

Jason Jorjani v. New Jersey Institute of Technology

Novartis Pharmaceuticals Corp v. Secretary United States Department of Health

Ellick, Elizabeth

A Different Form of Post-Op: Healing Survivors of Domestic Violence Through Prosecutorial Anatomy

2025 Decisions 
Opinions of the United 
States Court of Appeals 
for the Third Circuit 
3-11-2025 
In Re: Jake Bylsma 
Follow this and additional works at: https://digitalcommons.law.villanova.edu/thirdcircuit_2025 
Recommended Citation 
"In Re: Jake Bylsma" (2025). 2025 Decisions. 196. 
https://digitalcommons.law.villanova.edu/thirdcircuit_2025/196 
This March is brought to you for free and open access by the Opinions of the United States Court of Appeals for the 
Third Circuit at Villanova University Charles Widger School of Law Digital Repository. It has been accepted for 
inclusion in 2025 Decisions by an authorized administrator of Villanova University Charles Widger School of Law 
Digital Repository. For more information, please contact reference@law.villanova.edu. 
 
 
ALD-096        NOT PRECEDENTIAL 
UNITED STATES COURT OF APPEALS 
FOR THE THIRD CIRCUIT 
___________ 
 
No. 25-1307 
___________ 
 
IN RE: JAKE BYLSMA, 
    Petitioner 
____________________________________ 
 
On a Petition for Writ of Mandamus from the 
United States District Court for the Middle District of Pennsylvania 
(Related to M.D. Pa. Civ. No. 1:23-cv-00038) 
____________________________________ 
 
Submitted Pursuant to Rule 21, Fed. R. App. P. 
March 6, 2025 
 
Before: BIBAS, PORTER, and MONTGOMERY-REEVES, Circuit Judges 
 
(Opinion filed March 11, 2025) 
_________ 
 
OPINION* 
_________ 
 
PER CURIAM 
Pro se petitioner Jake Bylsma seeks a writ of mandamus relating to a civil rights 
case filed in the District Court.  Bylsma asks us to disqualify the District Court judge 
presiding over his case and to stay all District Court proceedings pending the outcome of 
this petition.  Because Bylsma has not demonstrated that he is entitled to such relief, we 
will deny his petition.  
 
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not 
constitute binding precedent. 
 
2 
 
In 2023, Bylsma filed a counseled complaint alleging Defendants had violated his 
First, Fourth, and Fourteenth Amendment rights.  After the District Court dismissed his 
sole claim against Defendant Crist, Bylsma’s counsel moved to withdraw.  The following 
day, Bylsma moved to dismiss his counsel and proceed pro se.  The District Court 
granted the counsel’s motion and denied Bylsma’s motion as moot. 
Bylsma then filed a motion to disqualify the District Judge for lack of impartiality 
under 28 U.S.C. § 455 because he was dissatisfied with the way the District Court had 
handled the motions and the service of orders. The District Judge declined to recuse 
herself from the case, finding that Bylsma had not shown that her impartiality could be 
questioned.  Bylsma then filed a motion for reconsideration of the order denying his 
motion to recuse, arguing again that the District Judge should recuse herself under § 455 
because she could not be impartial and also under 28 U.S.C. § 144 because she was 
biased against him.  The District Court denied his motion for reconsideration.  Bylsma 
appealed.  While that appeal was pending,1 Bylsma filed this petition for a writ of 
mandamus.   
To the extent that Bylsma brought his motion to recuse under 28 U.S.C. § 144, we 
have held that petitioners are precluded from using mandamus “to correct a district 
judge’s failure to disqualify himself or herself for actual bias.”  In re Sch. Asbestos Litig., 
977 F.2d 764, 776 (3d Cir. 1992).  To the extent Bylsma brought his motion to recuse 
 
1  We have since entered an order dismissing Bylsma’s appeal for lack of jurisdiction as 
his appeal sought review of a non-final decision in the District Court.  See Bylsma v. 
Masemer, No. 24-3098 (3d Cir. Feb. 10, 2025). 
 
3 
 
under 28 U.S.C. § 455, “[m]andamus is a proper means for this court to review a district 
court’s refusal to recuse from a case . . . where the judge’s impartiality might reasonably 
be questioned.”  Alexander v. Primerica Holdings, Inc., 10 F.3d 155, 163 (3d Cir. 1993).  
However, “[t]he writ of mandamus is an extreme remedy reserved for only the most 
extraordinary situations.”  In re Abbott Labs., 96 F.4th 371, 379 (3d Cir. 2024) (cleaned 
up).  We review a judge’s refusal to recuse for abuse of discretion.  In re Kensington Int'l 
Ltd., 368 F.3d 289, 300-01 (3d Cir. 2004). 
Bylsma has failed to point to anything in the record showing that the District 
Judge abused her discretion by failing to recuse.  See id. at 301-02 (discussing standard 
for disqualification).  Bylsma complains that the District Court directed him to provide 
his address even though he had previously done so and treated his affidavit of actual bias 
as an affidavit in support of his motion for reconsideration.  However, those assertions do 
not rise to the level that a reasonable person would conclude the District Judge’s 
impartiality might reasonably be questioned.  Moreover, as to Bylsma’s assertion that 
granting his former counsel’s motion to withdraw and then denying his own motion to 
dismiss his counsel as moot show a lack of impartiality, “a party’s displeasure with legal 
rulings does not form an adequate basis for recusal.”  Securacomm Consulting, Inc. v. 
Securacom Inc., 224 F.3d 273, 278 (3d Cir. 2000).   
For these reasons, we will deny the mandamus petition.2 
 
 
2  In light of our ruling, we deny Bylsma’s request for a stay of the District Court 
proceedings pending resolution of this petition.   


Villanova University

Not a member yet

USA v. Carl Rose

Jenn-Ching Luo v. Owen J Roberts School District

NRA Group LLC v. Nicole Durenleau

Abdulmalik Abdulla v. Attorney General United States

USA v. Marquis Smalls

Jason Jorjani v. New Jersey Institute of Technology

Novartis Pharmaceuticals Corp v. Secretary United States Department of Health

A Different Form of Post-Op: Healing Survivors of Domestic Violence Through Prosecutorial Anatomy

In Re: Jake Bylsma

Get Your Act Together: The Alternative Fines Act in Federal Prosecutions of Corporate Environmental Crimes

40,620

41,076