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

A Texas law, Senate Bill 1 (S.B. 1), related to voter registration and election integrity, was challenged by a group of plaintiffs (collectively referred to as LUPE) on the grounds that it chilled voter registration and was enacted with intent to discriminate against racial minorities. During the discovery phase of the lawsuit, LUPE sought documents and communications from the Harris County Republican Party (HCRP), which had been sent to or exchanged with the Texas Legislature and various members of the Texas executive branch regarding S.B. 1. The state defendants and non-party appellants (legislators) argued that some of these materials were protected by legislative privilege. The district court ruled that the legislative privilege did not apply.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court held that the legislative privilege was properly invoked and covered communications between the legislators and Alan Vera, the chair of the HCRP Ballot Security Committee, who had been involved in the legislative process relating to S.B. 1. The court further held that the legislative privilege did not yield under the circumstances of the case, as it did not meet the criteria for being an "extraordinary civil case" in which the privilege must yield. Therefore, the documents and communications sought by LUPE were protected by legislative privilege and not subject to discovery. View "La Union del Pueblo v. Bettencourt" on Justia Law

Thomas Rhone, a property owner in Texas City, Texas, had his apartments declared a nuisance by a Municipal Court of Record. Rhone disputed this decision in state court, but the City moved the case to federal district court. There, Rhone's claims were dismissed on summary judgment. Rhone appealed the district court's decision, challenging the standard of review and its conclusions regarding his constitutional claims. The United States Court of Appeals for the Fifth Circuit ordered a limited remand for the district court to conduct an evidentiary hearing on the role of the City Attorney in finalizing the Municipal Court’s order of abatement.Rhone's property, three apartment buildings, passed a city inspection in 2013 without any issues regarding a lack of a certificate of occupancy being raised. However, following an inspection in 2020, Texas City informed Rhone that his buildings were substandard and that he would need a certificate of occupancy to operate them. Rhone argued that city officials interfered with his efforts to remedy the violations claimed by the City and imposed conditions that made it impossible for him to preserve the value of his property by repairing the apartment buildings to bring them into compliance with the Texas City Code instead of demolishing the structures.After the city filed an administrative action in its Municipal Court of Record, the court ordered the demolition of the apartment buildings, finding them to be "dilapidated, substandard, unfit for human habitation, a hazard to the public health, safety, and welfare," and a nuisance. Rhone appealed this order in the 122nd Judicial District Court of Galveston County, but the City removed the action to the United States District Court for the Southern District of Texas in Galveston under federal-question jurisdiction. The federal district court ultimately granted partial summary judgment in favor of Texas City.The Court of Appeals held that any of Rhone's claims that would only interfere with the demolition of the buildings on his property were moot due to the demolition of the buildings. However, the court also held that the demolition did not eliminate a potential takings claim. The court ordered a limited remand for the district court to conduct an evidentiary hearing on the role of the City Attorney in finalizing the Municipal Court’s order of abatement. The court also held that Rhone has not shown that an initial inspection by a city fire marshal and an issuance of a citation that has consequences on his use of the property violate federal law. View "Rhone v. City of Texas City" on Justia Law

In this case, Larry Donnell Gibbs, a pro se plaintiff, filed a complaint under 42 U.S.C. § 1983 against five officers of the Texas Department of Criminal Justice. He alleged that two officers allowed him to bleed for 45 minutes after being stabbed by another inmate, and three other officers used excessive force against him in retaliation for filing a grievance about the incident. Gibbs attempted to proceed in forma pauperis, which would have allowed service to be made by a United States marshal, but the district court denied this on the basis that he had already paid the filing fee, had sufficient funds in his inmate trust account to serve the defendants, and had not provided the addresses of the defendants.The United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court found that the district court had abused its discretion by denying Gibbs's in forma pauperis status. It held that a person who is not a pauper at the commencement of a suit may become one during or prior to its prosecution. The court also found that the district court had arbitrarily determined that the funds in Gibbs's inmate trust account were sufficient for him to serve the defendants and that there's no requirement for an individual to be absolutely destitute to enjoy the benefit of in forma pauperis status. The court also held that a district court's determination of whether a party may proceed in forma pauperis must be based solely upon economic criteria and not on the lack of addresses for the defendants. The court concluded that the denial of Gibbs's in forma pauperis status had prejudiced his chances of effecting service. The case was remanded to the district court with instructions to permit Gibbs to proceed in forma pauperis. View "Gibbs v. Jackson" on Justia Law

In the case between Jennifer Harris and FedEx Corporate Services, Inc., Harris alleged race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964. The United States Court of Appeals for the Fifth Circuit found that Harris's § 1981 claims were time-barred under her employment contract, making them fail as a matter of law. However, the court found sufficient evidence to support the jury’s verdict for Harris on her Title VII retaliation claim. In view of Title VII’s $300,000 cap on damages and the evidence presented at trial, the court remitted Harris’s compensatory damages to $248,619.57 and concluded she was not entitled to punitive damages. FedEx was not entitled to a new trial because of the court’s evidentiary ruling. View "Harris v. FedEx Corporate Services" on Justia Law

In March 2019, the Waxahachie Police Department (WPD) SWAT Team mistakenly executed a search warrant on the wrong house, which was the home of Karen Jimerson, James Parks, and their two young children, instead of the intended target house. The error was due to Mike Lewis, the WPD SWAT Team Commander, incorrectly identifying the target house. The plaintiffs sued the officers under Section 1983 for violations of the Fourth Amendment and several state laws. The United States Court of Appeals for the Fifth Circuit reversed the district court's denial of summary judgment to Lewis on the issue of qualified immunity. The appellate court held that while Lewis's efforts to identify the correct residence were deficient, they did not violate clearly established law. The court found no genuine disputes of material fact, and it concluded that the disputed issue was one of law. The case was remanded for dismissal. View "Jimerson v. Lewis" on Justia Law

In a dispute between Conti 11 Container Schiffarts-GMBH & Co. KG M.S. and MSC Mediterranean Shipping Company S.A., the United States Court of Appeals for the Fifth Circuit found that the District Court for the Eastern District of Louisiana lacked personal jurisdiction over the case and reversed the district court's decision. The dispute arose from an incident where three chemical tanks exploded onboard a cargo vessel chartered by Conti to MSC, causing extensive damage and three deaths. After Conti won a $200 million award from a London arbitration panel, Conti sought to confirm the award in the Eastern District of Louisiana. MSC argued that the court lacked personal jurisdiction. The Fifth Circuit agreed with the district court’s assessment that when confirming an award under the New York Convention, a court should consider contacts related to the underlying dispute, not just those related to the arbitration itself. However, the Fifth Circuit disagreed with the district court's ruling that MSC waived its personal jurisdiction defense through its insurer’s issuance of a letter of understanding. The court also disagreed with the district court's finding that the loading of the tanks in New Orleans conferred specific personal jurisdiction over MSC, as this contact resulted from the actions of other parties not attributable to MSC. Therefore, the Fifth Circuit reversed the lower court's decision and remanded the case with instructions to dismiss it for lack of personal jurisdiction. View "Conti 11. Container Schiffarts-GMBH & Co. KG M.S. v. MSC Mediterranean Shipping Co. S.A." on Justia Law

This case arises from a trademark infringement dispute under the Lanham Act between Rolex Watch USA, Incorporated (Rolex) and Beckertime, L.L.C.; Matthew Becker (Beckertime). Rolex is a luxury watch seller with legally protectable interest in numerous trademarks. Beckertime sells primarily decades-old preowned watches containing Rolex branded parts, including watches identified as “Genuine Rolex,” but contain both Rolex and non-Rolex parts. The United States Court of Appeals for the Fifth Circuit affirmed in part, modified in part, and remanded in part the decision of the United States District Court for the Northern District of Texas.The district court found that Beckertime infringed Rolex’s trademark but refused to disgorge Beckertime of its profits, applying the laches defense. Rolex appealed, seeking a modification to the injunction, treble profits, and attorneys’ fees, while Beckertime sought the application of an alternative test to determine infringement.The Appellate Court upheld the district court's ruling that Beckertime infringed Rolex’s trademark, finding no clear error in the determination. The court affirmed the district court's decision to apply the laches defense, preventing the disgorgement of Beckertime's profits. The court found that Rolex had failed to offer a valid justification for its delay in filing suit and that Beckertime was prejudiced by this delay.Regarding remedies, the Appellate Court found that Rolex was not entitled to treble profits or attorneys’ fees. The court pointed out that Rolex had not moved for attorneys’ fees within the required time period under Federal Rule of Civil Procedure 54(d)(2), thereby waiving its right to such fees. Furthermore, the district court found no evidence of deliberate counterfeiting by Beckertime to warrant the imposition of treble profits.The court also addressed the scope of the injunction issued by the district court. It modified the injunction to prohibit the sale of Rolex watches with non-genuine bezels, but upheld the exclusion of all non-genuine dials from the injunction. The court also agreed with Rolex that the typographical errors in one section of the injunction rendered it vague and unqualified, and remanded the case to the district court for clarification. View "Rolex Watch v. Beckertime" on Justia Law

After being involved in a car accident, Kenan Watkins filed a diminished value claim with his insurer, Allstate Property and Casualty Insurance Company ("Allstate"), which was denied. Watkins then filed an action in the United States District Court for the Southern District of Mississippi, alleging that the denial of his claim violated Mississippi law. However, the district court ruled in favor of Allstate, holding that Allstate's policy did not violate Mississippi law and that Watkins failed to state a plausible claim, which led to Watkins' appeal to the United States Court of Appeals for the Fifth Circuit.In the background of the case, Watkins had an insurance policy with Allstate for his 2021 Chevrolet Tahoe. After the accident, Watkins' vehicle sustained substantial damages, and Watkins alleged that his car sustained an additional diminished value. Allstate denied Watkins' diminished value claim, relying upon a provision in its policy that excludes any decrease in the property's value resulting from the loss and/or repair or replacement. Watkins did not dispute this policy exclusion, but argued that Allstate's exclusion provision violates the Mississippi Uninsured Motorist Statute. Allstate moved to dismiss the case under Rule 12(b)(6), arguing that Watkins did not plausibly allege that the other driver's vehicle was an "uninsured motor vehicle" under Mississippi law, and that even if it was, Allstate's provision excluding diminished value is valid under Mississippi law.Upon review, the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court held that Watkins failed to make a plausible claim for relief under Rule 12(b)(6) due to insufficient factual content in the complaint. The court also held that Allstate’s diminished value exclusion is valid under Mississippi law and does not violate public policy. The court reasoned that Watkins had not pointed to any legislative or judicial pronouncement requiring that diminished value be a part of all automobile insurance policies. Therefore, in this instance, the plain meaning of Allstate’s policy controlled, and Allstate’s diminished value exclusion was upheld as valid under Mississippi law. View "Watkins v. Allstate Property & Casualty Insurance Co." on Justia Law

In this case, Trey Wooley filed a state court action against N&W Marine Towing (N&W) and others based on injuries he suffered while serving as a deckhand on the Mississippi River. The United States Court of Appeals for the Fifth Circuit held that Wooley had improperly joined N&W in the state court action in violation of a district court's stay order and the Limitation of Liability Act of 1851, which effectively ceased all claims and proceedings against N&W outside of a federal limitation action that N&W had previously filed. Therefore, N&W was dismissed as a defendant in the state court action. The court further held that, after dismissing N&W, there were no live claims remaining in the state court action because Wooley had previously settled his claims against the other defendants. Consequently, the court severed Wooley's state court action from the limitation action and dismissed it without prejudice. The court retained jurisdiction over the limitation action but stayed it to allow Wooley to pursue any viable claims against N&W in state court. The court concluded that the district court properly denied Wooley's motion to remand, as it had diversity jurisdiction over the case once N&W was dismissed. View "Wooley v. N&W Marine Towing" on Justia Law

The case revolves around the death of Rhonda Newsome, a pretrial detainee, who died in Anderson County Jail due to complications from Addison’s disease. Her family filed a lawsuit under 42 U.S.C. § 1983 against Anderson County, Sheriff Greg Taylor, Dr. Adam Corley, Nurse Timothy Green, and several jailers, alleging that the defendants violated Newsome’s Fourteenth Amendment rights as a pretrial detainee by failing to treat her chronic illness, resulting in her preventable death. The district court granted summary judgment for all Defendants and dismissed Plaintiffs’ lawsuit with prejudice. Upon review, the United States Court of Appeals for the Fifth Circuit found that Plaintiffs have established genuine disputes of material fact regarding whether several defendants violated Newsome’s clearly established constitutional rights. Thus, the court reversed the district court’s grant of summary judgment for several defendants, but affirmed the district court’s grant of summary judgment for others. The district court’s denial of Plaintiffs’ motion for leave to file a third amended complaint was also vacated, and instructions were given to grant Plaintiffs leave to amend their pleadings to include additional supervisory and municipal liability claims. Finally, the district court’s denial of Plaintiffs’ motion for sanctions was affirmed. View "Ford v. Anderson County" on Justia Law