Edwin Leon v. Nehama Hanoch

Court of Appeals for the Third Circuit·Decided February 19, 2026·No. 25-1240·Unpublished

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 25-1240

EDWIN LEON,

Appellant

v.

NEHAMA HANOCH;

CHEYENNE GOODMAN

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2:24-cv-01060)

District Judge: Hon. Wendy Beetlestone

Submitted Pursuant to Third Circuit L.A.R. 34.1(a)

November 14, 2025

Before: SHWARTZ, MATEY, and MONTGOMERY-REEVES, Circuit Judges

(Filed February 19, 2026)

OPINION*

*

This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent.

MATEY, Circuit Judge.

Edwin Leon appeals the dismissal of his claims against Nehama Hanoch and Cheyenne Goodman. Finding no error, we will affirm.1 Leon, Hanoch, and Goodman were employed by a law firm. A tumultuous relationship among the three followed culminating in Leon having separate interpersonal incidents with Hanoch and Goodman. Leon alleges that Goodman and Hanoch misinformed other firm employees about those incidents, resulting in Leon’s suspension. Goodman also filed a police report against Leon and obtained a protection from abuse order against Leon in Delaware state court. In granting that petition, the Delaware court found that Leon physically and verbally threatened and abused Goodman.

Leon then filed this lawsuit against Goodman and Hanoch alleging intentional infliction of emotional distress, negligent infliction of emotional distress, invasion of privacy, defamation, assault, and slander. The District Court granted Goodman and

Hanoch’s2 motions to dismiss, concluding, in relevant part, that the Delaware court’s factual findings precluded Leon’s claims.3 We agree because “[w]hen a prior case has been adjudicated in a state court, federal courts are required by 28 U.S.C. § 1738 to give full faith and credit to the state judgment.” Edmundson v. Borough of Kennett Square, 4 F.3d 186, 189 (3d Cir. 1993). As a result, the “doctrine of issue preclusion ordinarily bars relitigation of an issue of fact or law raised and necessarily resolved by a prior” state-court judgment. Bravo-Fernandez v. United States, 580 U.S. 5, 10 (2016). And, as the District Court properly held, “state court decisions [must] be given the same preclusive effect in federal court they would be given in the courts of the rendering state.” Del. River Port Auth. v. Fraternal Ord. of Police, 290 F.3d 567, 573 (3d Cir. 2002).

Leon’s arguments challenging the preclusive effect of the Delaware decision are unpersuasive. Leon’s argument that the “issue of defamation and the additional torts was not decided” in the Delaware action confuses issue preclusion and claim preclusion. Opening Br. 16 (emphasis omitted). “The doctrine of claim preclusion instructs that a final judgment on the merits ‘foreclos[es] successive litigation of the very same claim.’” Bravo-Fernandez, 580 U.S. at 9 (quoting New Hampshire v. Maine, 532 U.S. 742, 748 (2001)). Issue preclusion, by contrast, “bars relitigation of an issue of fact or law.” Id. at 10. The District Court did not hold that the Delaware commissioner adjudicated Leon’s

claims; it held that the Delaware commissioner adjudicated issues of fact arising from the incidents between Leon and Goodman. Because Leon’s defamation and slander claims are based on statements about events that the Delaware commissioner found to constitute acts of abuse by Leon toward Goodman, they cannot serve as a basis for those claims, as a true statement cannot be defamatory. See Pelagatti v. Cohen, 536 A.2d 1337, 1345-46 (Pa. Super. Ct. 1987). And Leon’s alternative argument that some issues against Goodman were not precluded was never adequately raised before the District Court, and so not properly argued on appeal. See Gass v. V.I. Tel. Corp., 311 F.3d 237, 246 (3d Cir. 2002). At best, Leon alluded to these other events, but a “casual mention” of a fact in a brief “is cursory treatment insufficient to preserve the issue on appeal.” Kost v. Kozakiewicz, 1 F.3d 176, 182 (3d Cir. 1993). Finally, any non-precluded allegations against Hanoch are insufficient to state a claim for defamation because they turn on “her feelings that she did not want to be friends with someone like [Leon] who treated her friend, [] Goodman, poorly,” App. 35, and an “opinion without more does not create a cause of action” for defamation, Baker v. Lafayette Coll., 532 A.2d 399, 402 (Pa. 1987).

* * *

For these reasons, we will affirm the District Court’s judgment.

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