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

Plaintiff appealed the district court's grant of summary judgment on her retaliation claim, which she claimed resulted from her complaints about sexual harassment. The court held that there were genuine disputes of material fact as to whether the conduct at issue created a hostile work environment in violation of Title VII, and, if so, whether plaintiff's complaint about that conduct was causally related to her termination. Accordingly, the court vacated and remanded for further proceedings, concluding that plaintiff had made out a prima facie case on her retaliation claim. View "Royal v. CCC& R Tres Arboles, L.L.C." on Justia Law

The Estate filed a malpractice suit against the deceased's health care providers under the Federal Tort Claims Act (FTCA), 28 U.S.C. 2671 et seq., alleging in part that they failed to provide appropriate follow-up care after discovering a mass in the deceased's stomach. The court affirmed the district court's grant of summary judgment for the United States based on its finding that the Estate's expert report failed to establish the relevant standard of care or create a question of fact as to the remaining elements of a malpractice claim under Mississippi law. View "Estate of Ira J. Sanders v. United States" on Justia Law

Carey Salt petitioned for review of the Board's decision finding that the company violated the National Labor Relations Act, 29 U.S.C. 158(a)(1), (3), and (5). The disputes underlying this case arose when the parties met to bargain over the terms of a new agreement that would replace the one that was expiring. The court enforced the order in part and vacated in part, concluding that substantial evidence on the record considered as a whole supported findings material to all terms of the order's mandate that Carey Salt cease and desist from presenting regressive bargaining proposals for the purpose of frustrating negotiations. View "Carey Salt Co. v. NLRB" on Justia Law

Petitioner, convicted of murdering three people and sentenced to death, appealed the district court's denial of his 28 U.S.C. 2254 application. At issue was whether petitioner was prejudiced by his counsel's deficient performance at trial because counsel allegedly failed to investigate potential mitigating evidence. Even assuming that the state habeas court unreasonably applied Strickland v. Washington's deficiency prong, the court was not persuaded that the state habeas court unreasonably applied the prejudice prong. The court concluded the state habeas court's decision was not contrary to, or an unreasonable application of, clearly established law and that the state habeas court's decision was not based on an unreasonable determination of the facts in light of the evidence. Accordingly, the court affirmed the judgment of the district court. View "Charles v. Stephens" on Justia Law

McLane filed suit to recover certain debts owed by Table Rock for goods and services provided by McLane. McLane also sought to recover debts from Scot Wederquist, owner of a 40% interest in and treasurer of Table Rock, by virtue of a guaranty agreement. On appeal, McLane challenged the district court's holding that Wederquist was not personally liable under the guarantee agreement. The court concluded that the guaranty only secured credit extended by PFS to its affiliates. Because McLane was not an affiliate of PFS, the Table Rock Debts were not secured by the guaranty. Accordingly, the court affirmed the judgment of the district court. View "McLane Foodservice Inc. v. Table Rock Restaurants, L.L.C., et al" on Justia Law

After SIC refused to defend or indemnify its insured, the City, in a lawsuit brought by WRI, the City settled the underlying litigation with WRI and sued SIC to recover defense costs, indemnification, and statutory penalty interest. The court concluded that SIC was liable for the City's defense costs where WRI's constitutional and tortious interference claims could produce liability that did not arise out of WRI's inverse condemnation action; the court remanded for the district court to allow the parties to introduce evidence regarding SIC's indemnity obligation where the pleadings did not raise a possibility of municipal liability independent of any just-compensation liability arising out of WRI's inverse condemnation action; the court remanded for the district court to assess the penalty interest under section 542.058 of the Texas Insurance Code; and, because it was not yet clear whether the City would prevail on its indemnity claim, or how much of the City's attorney's fees were attributable to litigating the indemnity claim, the court concluded that the district court could determine whether there was any fee award under section 38.001 of the Texas Civil Practice and Remedies Code. Accordingly, the court reversed and remanded for further proceedings. View "City of College Station, Texas v. Star Ins. Co." on Justia Law

Plaintiff filed suit against the United States and others, alleging violations of her religious rights under Title VII, 42 U.S.C. 2000e et seq., and the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb et seq. Plaintiff lost her job by failing to comply with the applicable regulations or to receive an appropriate waiver when she wore a kirpan (a Sikh ceremonial sword) to work. The court affirmed the district court's grant of summary judgment on plaintiff's Title VII claim where her employer's, the IRS, failure to accommodate plaintiff did not violate Title VII as a matter of law. The court reversed and remanded plaintiff's RFRA claim for further development of evidence concerning the government's compelling interest in enforcing against plaintiff the statutory ban on weapons with blades exceeding 2.5 inches. View "Tagore v. United States" on Justia Law

Defendant appealed his conviction for violations of federal drug and gun laws. The court rejected defendant's Batson challenge, concluding that, for Juror 23 and 37, the district court found the prosecutor's demeanor-based justification credible. The court also concluded that the evidence was sufficient for a rational jury to find that defendant was a voluntary participant in a drug conspiracy and that defendant possessed firearms in furtherance of a drug-trafficking crime. Accordingly, the court affirmed the conviction. View "United States v. Thompson" on Justia Law

Plaintiffs, console supervisors at a refinery, alleged that their employer, CITGO, misclassified them as exempt from the overtime payment requirements of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-219. The district court subsequently granted summary judgment for CITGO based on plaintiffs' inability to prove damages but reduced CITGO's award of taxable costs. Both parties appealed. The court affirmed the district court's discovery sanctions dismissing seventeen plaintiffs (the January Sanction); discovery sanctions dismissing four additional plaintiffs (the March Sanction); and dismissal of the three remaining plaintiffs after preventing them from testifying about damages. The court concluded, however, that it was not entirely evident whether the district court intended plaintiffs' limited resources to be an independent basis for the cost reduction or whether, instead, it was a dependent part of a comparative-wealth analysis. Accordingly, the court reversed the order reducing costs and rendered in favor of CITGO for $53,065.72. View "Moore, et al. v. CITGO Refng. & Chem. Co., L.P." on Justia Law

BPRE filed for Chapter 11 bankruptcy relief and then filed an adversary complaint in the bankruptcy court alleging various state-law tort and contract claims against RML. The bankruptcy court entered a final judgment denying relief and the district court affirmed. In Stern v. Marshall, the Supreme Court determined that the bankruptcy court lacked the constitutional authority to enter final judgment on the debtor's state-law counterclaim even thought the statute conferred such authority. Although the strict holding in Stern limited bankruptcy-court authority in one isolated respect and the question presented was a narrow one, its sweeping reasoning was broad and logically must be applied to BPRE's claims here. Therefore, the court vacated the district court's judgment and remanded, concluding that the bankruptcy court lacked Article III standing to enter final judgment on BPRE's claims. View "BP RE, L.P. v. RML Waxahachie Dodge, L.L.C., et al." on Justia Law