Wheeler Zamichieli v. William Andrews

CourtCourt of Appeals for the Third Circuit
DecidedJuly 19, 2024
Docket21-2522
StatusUnpublished

This text of Wheeler Zamichieli v. William Andrews (Wheeler Zamichieli v. William Andrews) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wheeler Zamichieli v. William Andrews, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 21-2522 __________

WHEELER ZAMICHIELI, Appellant

v.

POLICE OFFICER WILLIAM ANDREWS; POLICE OFFICER MELVIN VICTOR; THE CITY OF PHILADELPHIA; RONALD DOVE; JOHN VERRECCHIO; JAMES PITTS; GEORGE FETTERS; WILLIAM GALLAGHER; JOHN DOE BADGE B380; JOHN DOES 1-10 __________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2-12-cv-03200) District Judge: Honorable Eduardo C. Robreno __________

Argued on November 6, 2023

Before: RESTREPO, BIBAS, and SCIRICA, Circuit Judges

(Filed: July 19, 2024)

Tadhg Dooley David R. Roth WIGGIN & DANA One Century Tower 265 Church Street New Haven, CT 06510

David Herman [ARGUED] Varshini Parthasarathy [ARGUED] YALE LAW SCHOOL ADVANCED APPELLATE LITIGATION PROJECT 127 Wall Street New Haven, CT 06511 Counsel for Appellant

Meghan Byrnes Zachary G. Strassburger [ARGUED] CITY OF PHILADELPHIA LAW DEPARTMENT 1515 Arch Street Philadelphia, PA 19102

John J. Hare Shane Haselbarth [ARGUED] MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN 2000 Market Street, Ste. 2300 Philadelphia, PA 19103 Counsel for Appellees ___________

OPINION * ___________

RESTREPO, Circuit Judge.

Judicial economy does not excuse cutting corners, even in the most frustrating of

circumstances. Wheeler Zamichieli, a largely pro se and incarcerated litigant whose case

has languished for over twelve years, seeks to vindicate his civil rights following what one

judge deemed an unconstitutional search and seizure. But another judge later granted

summary judgment against him by ignoring material evidence that he should have inferred

in Mr. Zamichieli’s favor. Because ignoring that evidence was reversible error, we will

vacate the District Court’s judgment and remand his case for additional proceedings.

* This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent. 2 I

The government charged Mr. Zamichieli in 2011 with unlawful possession of a

firearm under 18 U.S.C. §922(g)(1) after a Philadelphia police officer claimed that he saw

a handgun in plain view during a routine traffic stop. At the ensuing suppression hearing,

the involved officers gave conflicting testimony suggesting that Mr. Zamichieli had—early

one February morning—turned on his car’s interior lights and rolled down his darkly tinted

driver-side window, allowing one officer to see a firearm on the front passenger seat. In

stark contrast, Mr. Zamichieli testified that the gun was hidden under the seat and that the

officers, without probable cause, had approached his vehicle with guns drawn, pulled him

out at gunpoint, handcuffed him against a patrol car, and rummaged through the vehicle,

eventually finding the firearm. Judge Berle M. Schiller credited Mr. Zamichieli’s testimony

about the weapon’s location, finding the officers’ version of the story “implausible.”

United States v. Zamichieli, No. 11-CR-393, 2011 WL 6133352, at *2 (E.D. Pa. Dec. 9,

2011). With the firearm suppressed, the government dismissed the case and freed Mr.

Zamichieli after over five months in jail.

That turned out to be only act one of a three-part story. While detained on the first

gun charge, the government was able to surveil Mr. Zamichieli’s personal phone calls. In

one call, he brazenly asked his then-fiancée to retrieve a second gun from his still-

impounded vehicle and sell it. Prosecutors again charged Mr. Zamichieli under § 922(g)(1).

After two trials before two different judges, two successful appeals, dozens of pro se

filings, and extended periods of self-representation, a jury ultimately convicted Mr. 3 Zamichieli. But his admirable persistence over the last decade ensured that the sentence he

served—120 months—was lower than the 210 months originally (and incorrectly)

mandated. He returned home in 2023.

The third and final act is at issue here. In response to his experience with law

enforcement, Mr. Zamichieli filed a civil rights complaint pursuant to 42 U.S.C. § 1983

nearly twelve years ago. The case, first assigned to Judge Eduardo C. Robreno, was

reassigned to Judge Gregory M. Sleet of the District of Delaware in June 2013. Judge Sleet

presided over the case until it was returned to Judge Robreno in March 2020, just as the

COVID-19 pandemic hit. Throughout the case’s lengthy history, Mr. Zamichieli has

amended his complaint four times and the parties have clashed extensively over discovery.

And for much of it, Mr. Zamichieli has either gone unrepresented or struggled with

establishing a productive relationship with his counsel. 1 Simply put, and for a variety of

reasons, Mr. Zamichieli’s case has not moved through our justice system with ease.

Given these extensive delays, it should come as no surprise that by October 2020

Judge Robreno sought to fast-track the matter and called for a joint deposition of Mr.

Zamichieli. In that deposition, Mr. Zamichieli, who was unable to contact his criminal

defense attorney to discuss possible overlap between this case and his then-ongoing second

criminal appeal, invoked his Fifth Amendment privilege in response to all questions about

1 We are grateful to pro bono counsel and to the Yale Law School students they supervised for stepping in to assist Mr. Zamichieli at this stage. No matter the outcome, our system benefits tremendously when all litigants, irrespective of circumstance, have access to excellent representation that makes them feel heard. 4 the location of the gun in his vehicle. After the deposition, the defendants moved for

summary judgment on all counts. The District Court granted it, finding that the record

could not support Mr. Zamichieli’s claims. Specifically, it found that there was no dispute

of material fact regarding the gun’s location since Mr. Zamichieli had invoked his right to

remain silent every time the topic was raised. Although Mr. Zamichieli’s brief opposing

summary judgment referred to his 2011 suppression testimony, the District Court declined

to consider it and only described his reticence at the more recent deposition.

II

We have jurisdiction pursuant to 28 U.S.C. § 1291 and review the District Court’s

grant of summary judgment de novo. Giles v. Kearney, 571 F.3d 318, 322 (3d Cir. 2009).

Summary judgment is only appropriate where “there is no genuine dispute as to any

material fact.” Fed. R. Civ. P. 56(a). “A dispute is genuine ‘if the evidence is such that a

reasonable jury could return a verdict for the nonmoving party.’” SodexoMAGIC, LLC v.

Drexel University, 24 F.4th 183, 203–04 (3d Cir. 2022) (quoting Anderson v. Liberty

Lobby, Inc., 477 U.S. 242, 248 (1986)). A factual dispute is “material” if it has “the

potential to affect the outcome of the suit.” Id. at 204. And “in assessing the genuineness

of a potential factual dispute, inferences from the underlying facts should be drawn in favor

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Giles v. Kearney
571 F.3d 318 (Third Circuit, 2009)
Childers v. Joseph
842 F.2d 689 (Third Circuit, 1988)

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Wheeler Zamichieli v. William Andrews, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wheeler-zamichieli-v-william-andrews-ca3-2024.