The U.S. Court of Appeals for the Third Circuit issued a non-precedential opinion rejecting a lawsuit filed by University of Pennsylvania faculty members who sought to prevent the university from producing documents to a congressional committee investigating campus antisemitism.
The case, *Huda Fakhreddine v. University of Pennsylvania* (3d Cir. 2026), involved faculty members Huda Fakhreddine and Eve Troutt Powell, along with Penn Faculty for Justice in Palestine, who sued the university after it began complying with congressional document requests following a high-profile hearing on campus antisemitism.
According to the Third Circuit opinion authored by Circuit Judge Allison Jones Rushing, the legal dispute arose after two congressional representatives questioned a University of Pennsylvania president about antisemitism on campus during a congressional hearing. During their questioning, the congressmen specifically referenced faculty members, campus groups, and on-campus events related to the antisemitism controversy.
Following the hearing, the congressional committee formally requested documents from the university related to its handling of antisemitism incidents and campus speech policies. The university began producing the requested documents in compliance with the congressional request.
The plaintiffs argued that one of the referenced professors had already received negative publicity after the congressional hearing. Fearful that the university's document production would intensify unwanted attention and potentially provoke harassment against faculty members, the group filed suit in the U.S. District Court for the Eastern District of Pennsylvania.
The lawsuit alleged violations of federal civil rights laws and included claims under state law. The faculty members initially sought injunctive relief to prevent the university from producing any documents to the congressional committee. They later amended their complaint to also request monetary damages from the university.
District Judge Mitchell S. Goldberg initially heard the case, which was designated as case number 2:24-cv-01034. The district court's ruling prompted the faculty members to appeal to the Third Circuit, where the case was assigned number 25-1290.
The Third Circuit panel consisted of Circuit Judges Stephanos Bibas, Louis Felipe Restrepo, and Allison Jones Rushing. The case was submitted pursuant to Third Circuit Local Appellate Rule 34.1(a), which governs certain streamlined appeal procedures.
The appeals court heard oral arguments on December 11, 2025, and issued its opinion on January 9, 2026. The court designated the opinion as "not precedential," meaning it does not establish binding legal precedent for future cases but resolves the specific dispute before the court.
The faculty plaintiffs' legal challenge represented an unusual intersection of congressional oversight powers, university autonomy, and faculty speech rights. The case highlighted tensions that emerged on university campuses nationwide following increased scrutiny of how institutions handle antisemitism and related campus speech issues.
Penn Faculty for Justice in Palestine, one of the organizational plaintiffs, had been among the campus groups specifically mentioned during the congressional hearing that triggered the document requests. The group's involvement in the lawsuit underscored broader debates about academic freedom and institutional responses to congressional investigations.
The University of Pennsylvania faced significant public attention regarding its handling of campus antisemitism issues, including incidents involving faculty statements and campus events. The congressional hearing referenced in the case was part of broader legislative oversight efforts examining how universities address antisemitism and related campus climate concerns.
The Third Circuit's rejection of the faculty lawsuit means the University of Pennsylvania can continue producing documents to the congressional committee without court-ordered restrictions. The ruling also leaves the faculty members without the injunctive relief they sought to prevent document disclosure or the damages they later requested.
The case reflects ongoing tensions between congressional oversight authority and claims of academic freedom and faculty rights. Universities nationwide have faced similar congressional scrutiny regarding their handling of campus antisemitism and speech policies, particularly following high-profile incidents and controversies.
Legal experts note that the non-precedential nature of the Third Circuit's opinion limits its broader impact on similar disputes. However, the ruling provides insight into how federal courts may approach future challenges to congressional oversight of university policies and practices.
The lawsuit's resolution removes a legal obstacle to ongoing congressional investigation of campus antisemitism issues at the University of Pennsylvania. The case demonstrates the complex legal landscape universities navigate when balancing faculty concerns, institutional autonomy, and congressional oversight responsibilities.
Neither the plaintiffs nor the University of Pennsylvania immediately responded to requests for comment regarding the Third Circuit's decision. The ruling concludes the federal court litigation, though the underlying congressional investigation may continue as the committee reviews documents produced by the university.