Justia U.S. 5th Circuit Court of Appeals Opinion Summaries

Law enforcement in New Orleans began investigating a suspected methamphetamine dealer in 2020, leading them to Marshall Grace through surveillance methods such as phone records and tracking devices. Officers stopped Grace’s vehicle after observing traffic violations, detected the smell of marijuana, and subsequently searched his vehicle, finding approximately 441 grams of methamphetamine. Grace was arrested and provided a written statement admitting ownership of the drugs and detailing his ongoing involvement in distributing methamphetamine to others, including regular transactions over a two-year period. Electronic evidence from his phones corroborated his admissions and established communication with other dealers.The United States District Court for the Eastern District of Louisiana presided over Grace’s trial. During jury selection, the government used peremptory strikes to exclude two of five black potential jurors, including one named Edward Davis. Grace challenged the exclusion of Davis under Batson v. Kentucky, arguing it was racially motivated. The district court questioned Davis and ultimately found the government’s reason—Davis having seven sons, one of whom had criminal justice involvement—to be race-neutral and denied Grace’s Batson challenge. The trial concluded with the jury finding Grace guilty on all counts, and the court imposed the statutory minimum sentence. Grace appealed, contesting both the sufficiency of the evidence for his conspiracy conviction and the denial of his Batson challenge.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held there was sufficient evidence to support the conspiracy conviction, given Grace’s admissions, corroborating testimony, and the quantity of drugs involved. The appellate court also found no clear error in the district court’s denial of the Batson challenge, ruling that Grace failed to show purposeful discrimination by the prosecution. The Fifth Circuit affirmed the district court’s judgment in full. View "USA v. Grace" on Justia Law

Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded for the district court to decide whether the right was clearly established.On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established. The officers appealed. The United States Court of Appeals for the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Thus, Coborn was not entitled to qualified immunity for the second round of shots. View "Baker v. Coborn" on Justia Law

A woman who was pregnant while detained at the Tarrant County Jail gave birth in her cell two weeks before her due date. The infant was found stuck in her pants and was transported to the hospital, where the child died ten days later. The Medical Director at the jail, a physician who did not provide direct care to inmates in the female infirmary, had issued orders for the treatment of pregnant inmates but relied on other medical staff to carry out those orders. Days before the birth, the woman was seen by an OB/GYN, who noted her communication difficulties and recommended an elective induction of labor at 39–40 weeks, which the Medical Director approved. On the day of the birth, the woman was mentioned in the attachment to a nursing report email regarding abdominal cramps and refusal of breakfast, but not in the body of the email. The Medical Director stated he did not read the attachment before learning the birth had occurred.After the incident, the woman, through her guardian, filed suit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Texas, alleging the Medical Director denied her adequate medical care in violation of the Fourteenth Amendment. Following discovery, the Medical Director moved for summary judgment, asserting qualified immunity and arguing he lacked subjective knowledge of a substantial risk of serious harm. The district court granted summary judgment for the Medical Director and denied the plaintiff’s cross-motion.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court held that the Medical Director did not have subjective knowledge of a substantial risk of serious harm to the detainee and therefore did not act with deliberate indifference. The court affirmed the district court’s summary judgment in favor of the Medical Director. View "Congious v. Shaw" on Justia Law

The plaintiff, Michael Hagar, is an individual convicted of cyberstalking and making interstate threats. He submitted a Freedom of Information Act (FOIA) request to the Federal Bureau of Investigation (FBI) for a copy of a specific email he sent in 2016, which became part of the FBI’s investigation. Hagar specifically sought the unredacted “To” line of recipients and the email’s complete header information, which includes technical metadata such as server paths and timestamps. The FBI initially provided the email with recipient information redacted, citing privacy exemptions, and declined to produce the header metadata, arguing it would require the creation of a new record.Following his FOIA request, Hagar filed a pro se lawsuit in the United States District Court for the Eastern District of Texas. The magistrate judge terminated Hagar’s initial summary judgment motion as premature, set a schedule for further briefing, and allowed the FBI to move for summary judgment. After the FBI sent Hagar an unredacted copy of the email, the magistrate judge recommended granting summary judgment for the FBI, agreeing that the header information would require creation of a new record and, alternatively, was exempt under FOIA. The district court adopted this recommendation, entered judgment for the FBI, and denied Hagar’s post-judgment motions and misconduct claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that because Hagar had received the “To” line information, his claim for that was moot. The court further held that FOIA does not require agencies to create new records to satisfy requests, and thus the FBI was not obligated to produce the header information. The court affirmed the district court’s rulings, including denial of post-judgment motions, and dismissed Hagar’s judicial misconduct claims as meritless. View "Hagar v. FBI" on Justia Law

Two development companies owned land in Johnson County, Texas, within the extraterritorial jurisdiction of the City of Mansfield but outside the city’s corporate boundaries. To develop this land, the companies needed access to retail water services, which, under state law, could be provided only by the Johnson County Special Utility District (“JCSUD”) because it held the exclusive certificate of convenience and necessity (CCN) for the area. However, a contract between JCSUD and the City of Mansfield required JCSUD to secure Mansfield’s written consent, which could be withheld at the City’s discretion, before providing water services within the city’s extraterritorial jurisdiction. The developers’ efforts to obtain water service were unsuccessful, as Mansfield demanded annexation and additional fees, ultimately refusing to formalize an agreement.After unsuccessful negotiations and attempts to compel service through the Texas Public Utility Commission, the developers sued the City of Mansfield in the United States District Court for the Northern District of Texas. They alleged violations of the Sherman Act and brought state-law claims. The district court, adopting a magistrate judge’s recommendation, dismissed the antitrust claims with prejudice, holding that Mansfield was entitled to state-action antitrust immunity under Texas law, and declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed whether Mansfield was entitled to state-action immunity. The Fifth Circuit held that, although Texas law authorizes monopolies for water utilities through CCNs, it does not clearly articulate or authorize the City of Mansfield to act anticompetitively concerning the area in question, since the CCN belonged to JCSUD. Therefore, the court reversed the district court’s grant of state-action immunity and remanded the case for further proceedings. View "Megatel v. Mansfield" on Justia Law

The Securities and Exchange Commission initiated an enforcement action against Timothy Barton and related entities, alleging violations of federal securities laws. The district court subsequently appointed a receiver to manage properties allegedly acquired with funds from Barton’s fraudulent activities. Certain properties and entities, including TC Hall, LLC (owner of the Hall Street property), Goldmark Hospitality LLC (owner of Amerigold Suites), BM318, LLC, and JMJ Development, LLC, were placed within the receivership because they had received or benefitted from assets traceable to the alleged misconduct.The United States District Court for the Northern District of Texas oversaw the receivership and issued several orders approving property sales and settlements. Barton previously appealed the appointment of the receivership and its scope. The United States Court of Appeals for the Fifth Circuit, in an earlier decision (SEC v. Barton, 79 F.4th 573 (5th Cir. 2023)), vacated and remanded for reconsideration; on remand, the district court narrowed and reappointed the receivership. The Fifth Circuit later affirmed the new receivership order in SEC v. Barton, 135 F.4th 206 (5th Cir. 2025). While appeals were pending, the district court issued orders related to the sale of Amerigold Suites, settlements involving JMJ and BM318, and the sale of the Hall Street property.In the current appeal, the United States Court of Appeals for the Fifth Circuit concluded it lacked appellate jurisdiction to review the cancelled Amerigold Suites sale and the two settlement agreements, dismissing those portions of the appeal. The court found jurisdiction to review the approval of the Hall Street property sale and affirmed the district court’s order, holding that the district court did not abuse its discretion in approving the sale, which complied with statutory requirements and was in the best interest of the receivership estate. View "Securities and Exchange Commission v. Barton" on Justia Law

A professional pilot was asked to operate a Cessna Citation 550 aircraft whose tail number had recently been changed by its owner from N550ME to N550MK. The Federal Aviation Administration (FAA) approved the new registration and issued new documents, but denied a new airworthiness certificate because the aircraft required further inspection. Believing the registration had reverted to the old number due to the denial, the owner had the physical tail number altered back to N550ME using tape, while the aircraft carried documents for both the old and new registrations. The pilot, after being told about “paperwork issues” and noticing the taped number, proceeded to fly the aircraft on two flights without confirming the correct registration and without a valid airworthiness certificate for the current registered tail number. After the first flight, FAA inspectors issued a written notice warning that further operation would violate federal regulations; the pilot disregarded this and completed the return flight.The FAA suspended the pilot’s license for 150 days, citing violations of various regulations requiring proper display of the registered tail number and possession of a valid airworthiness certificate. The pilot appealed the suspension to the National Transportation Safety Board (NTSB), where an Administrative Law Judge affirmed the FAA’s order after a hearing. The full NTSB then affirmed the ALJ’s decision.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a deferential standard to the agency’s findings and sanction. The court held that the NTSB’s decision was not arbitrary or capricious. The court concluded that the pilot’s reliance on the owner’s explanation was unreasonable and that the penalty was not excessive, even if the violations were administrative. The court also found no improper disparity in sanctioning compared to another pilot. The petition for review was denied, and the suspension was upheld. View "Hardwick v. FAA" on Justia Law

Intuit, Inc., the seller of TurboTax tax-preparation software, advertised its “Free Edition” as available at no cost for “simple tax returns.” However, the majority of taxpayers did not qualify due to various exclusions, and those individuals were prompted during the tax preparation process to upgrade to paid products. The Federal Trade Commission (FTC) brought an administrative complaint in 2022, alleging that these advertisements were deceptive under Section 5 of the FTC Act. After an initial federal court suit for a preliminary injunction was denied, the FTC pursued the matter through its internal adjudicative process instead.An Administrative Law Judge (ALJ) concluded that Intuit’s advertisements were likely to mislead a significant minority of consumers. The FTC Commissioners affirmed this decision, issuing a broad cease-and-desist order that barred Intuit from advertising “any goods or services” as free unless it met stringent requirements. This order was not limited to tax-preparation products. Intuit petitioned the United States Court of Appeals for the Fifth Circuit for review, asserting, among other arguments, that the FTC’s adjudication of deceptive advertising claims through an ALJ, rather than an Article III court, was unconstitutional.The United States Court of Appeals for the Fifth Circuit held that deceptive advertising claims under Section 5 of the FTC Act are akin to traditional actions at law or equity, such as fraud and deceit, and thus involve private rights. According to recent Supreme Court precedent in SEC v. Jarkesy, such claims must be adjudicated in Article III courts, not by agency ALJs. The Fifth Circuit granted Intuit’s petition, vacated the FTC’s order, and remanded the case to the agency for further proceedings consistent with its holding. View "Intuit v. Federal Trade Commission" on Justia Law

An 18-year-old high school senior from Texas was indicted by a federal grand jury for transmitting threats in interstate commerce, based on statements he made while using the online gaming platform Roblox. The statements, made in a virtual “Church” experience, referenced possessing firearms, preparing munitions, and intentions to commit violence at a Christian event. Other Roblox users, located in Pennsylvania and Nevada, reported these statements to the FBI, believing them to be serious threats rather than mere role-play or trolling. The government alleged the defendant's remarks corresponded to a real concert scheduled in Austin and supported its case with evidence from the defendant’s internet history and statements captured by a keylogger.The United States District Court for the Western District of Texas dismissed the indictment before trial, concluding no reasonable juror could find that the defendant’s statements constituted “true threats” outside the protection of the First Amendment. The court found the context—a role-playing video game environment filled with extreme and offensive avatars—undermined the seriousness of the statements, and excluded evidence of the defendant’s conduct outside Roblox as irrelevant. The district court released the defendant without conditions, later imposing some conditions after a government request.On appeal, the United States Court of Appeals for the Fifth Circuit held that the question of whether the statements were “true threats” is a factual issue that should ordinarily be decided by a jury at trial, not by the judge on a pretrial motion. The court found that disputed facts and contextual uncertainties required a trial on the merits, and that the district court erred by resolving these issues prematurely. The Fifth Circuit reversed the district court’s dismissal of the indictment and remanded for further proceedings. The appeal regarding the defendant’s release was dismissed as moot. View "United States v. Burger" on Justia Law

A police officer suffered severe injuries during a protest in Baton Rouge, Louisiana, when a demonstrator threw a heavy object that struck him in the face. The protest was organized in response to police conduct and was led by a prominent activist who had previously participated in similar events that sometimes turned violent. On the day of the incident, the leader was observed directing protestors, including leading them onto a highway and not discouraging violent behavior as the situation escalated. The officer’s injuries were significant, resulting in lasting physical and psychological harm and the end of his law enforcement career.The officer sued the activist, Black Lives Matter, and related entities in the United States District Court for the Middle District of Louisiana, alleging negligence and other tort claims. The district court dismissed most of the claims with prejudice, but the United States Court of Appeals for the Fifth Circuit reversed as to the negligence claim against the activist. The Supreme Court of the United States vacated that decision, remanding for clarification of Louisiana negligence law. The Supreme Court of Louisiana confirmed that state law recognizes a duty not to negligently precipitate third-party crimes under the circumstances alleged. After further proceedings, the district court again granted summary judgment for the activist, finding no duty, lack of causation, and First Amendment protection.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court’s summary judgment. The court held that there is sufficient evidence for a jury to consider whether the activist’s leadership and actions breached a duty of care and were a cause-in-fact of the officer’s injuries, and that such a claim is not foreclosed by the First Amendment. The case was remanded for trial. View "Ford v. Mckesson" on Justia Law