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

Highland Capital Management, L.P., a Dallas-based investment firm, filed for Chapter 11 bankruptcy in 2019 due to numerous unpaid judgments and liabilities. During the bankruptcy proceedings, James Dondero, a co-founder, stepped down as a director and officer but continued as an unpaid portfolio manager. The unsecured creditors' committee and independent directors opposed Dondero's reorganization plans, leading to his resignation in October 2020. The bankruptcy court held Dondero in civil contempt and sanctioned him for obstructing the proceedings. The proposed reorganization plan included provisions to shield Highland Capital and associated entities from liability, including an Exculpation Provision and an Injunction Provision with a Gatekeeper Clause.The bankruptcy court confirmed the plan, but on direct appeal, the United States Court of Appeals for the Fifth Circuit reversed the plan in part, striking certain non-debtors from the Exculpation Provision. The investment fund parties requested clarification on whether the same entities should be removed from the Gatekeeper Clause. The bankruptcy court conformed the plan by narrowing the definition of "Exculpated Parties" but did not change the definition of "Protected Parties" in the Gatekeeper Clause, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the bankruptcy court failed to implement its instructions properly. The court held that the definition of "Protected Parties" in the Gatekeeper Clause must be narrowed to include only the Debtor, the Independent Directors for conduct within their duties, the Committee, and the members of the Committee in their official capacities. The court reversed the bankruptcy court's decision in part and remanded the case for the plan to be revised accordingly. View "Highland Capital Fund Advisors v. Highland Capital Management" on Justia Law

Jessie Hoffman was convicted of first-degree murder for the kidnapping, rape, and murder of Mary "Molly" Elliot in 1998 and sentenced to death. After exhausting all state and federal post-conviction remedies, his execution was delayed due to the unavailability of lethal injection drugs. In 2024, Louisiana adopted nitrogen hypoxia as a method of execution. Hoffman challenged this new method, arguing it violated the Eighth Amendment.The United States District Court for the Middle District of Louisiana granted Hoffman's motion for a preliminary injunction, preventing his execution by nitrogen hypoxia. The court concluded that Hoffman had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA) and found that nitrogen hypoxia posed a substantial risk of superadding pain and suffering. The court suggested that execution by firing squad would be a reasonable alternative that would reduce the risk of severe pain.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that Hoffman had indeed exhausted his administrative remedies. However, it disagreed with the district court's conclusion regarding the Eighth Amendment. The Fifth Circuit held that nitrogen hypoxia is painless and that the district court erred in suggesting that the Eighth Amendment requires a more painful method of execution, such as a firing squad. The court emphasized that the Eighth Amendment does not guarantee a painless death and that Hoffman failed to show that nitrogen hypoxia presented a substantial risk of severe pain compared to other methods.The Fifth Circuit vacated the preliminary injunction, allowing Louisiana to proceed with Hoffman's execution by nitrogen hypoxia. View "Hoffman v. Westcott" on Justia Law

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation. View "Doe v. Charter Communications" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act.The United States District Court for the Southern District of Texas tried the case. After a five-day trial, the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez argued that the evidence was insufficient to support his convictions, but the court found that the evidence, including his interactions with runners and knowledge of Lightner's prescribing practices, was sufficient. Lightner raised several issues, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found no reversible error in these claims.The court also reviewed the sentencing enhancements applied to Lightner, including the calculation of drug weight, a two-level premises enhancement, and a four-level leadership enhancement. The court found that the evidence supported these enhancements and that any potential error was harmless given the substantial downward variance in Lightner's sentence.The Fifth Circuit affirmed the district court's judgment, finding no reversible error in the convictions or sentences of Martinez and Lightner. View "United States v. Lightner" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act and pleaded not guilty.The United States District Court for the Southern District of Texas conducted a five-day trial, after which the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez challenged the sufficiency of the evidence for his convictions, but the court found the evidence sufficient to support the jury's verdicts. The court noted that Martinez's involvement with runners and his knowledge of Lightner's prescribing practices indicated his participation in the conspiracy. The court also upheld Martinez's conviction under Pinkerton liability for the substantive count.Lightner raised several issues on appeal, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found that while the jury instructions contained an error, it did not affect Lightner's substantial rights due to the ample evidence of his unlawful prescribing practices. The court also found no abuse of discretion in the district court's handling of the spoliation claim and the witness testimony.Regarding sentencing, the court upheld the district court's calculations of drug weight and the application of enhancements for maintaining a premises for drug distribution and for Lightner's leadership role in the conspiracy. The court affirmed the district court's judgment in all respects. View "United States v. Martinez" on Justia Law

ExxonMobil Technology and Engineering Company (Exxon) operates a research facility in New Jersey where approximately 165 employees are represented by the Independent Laboratory Employees Union (the Union). The collective bargaining agreement (CBA) between Exxon and the Union expired in May 2018. During negotiations for a new CBA, disputes arose over Exxon’s personal time off (PTO) policies and paid parental leave (PPTO). The Union wanted to restore a policy allowing supervisors to review PTO requests and sought eight weeks of PPTO for its members. Exxon refused to negotiate on these issues, citing concerns over inconsistencies and potential grievances.An administrative law judge (ALJ) found that Exxon violated the National Labor Relations Act by refusing to bargain in good faith on the supervisor PTO review issue, retaliating against the Union for past grievances, and suggesting that employees would receive PPTO if they decertified the Union. The National Labor Relations Board (NLRB) initially reversed the ALJ’s findings in a 2020 decision. However, it was later discovered that a Board member involved in the decision had a conflict of interest, leading the NLRB to vacate the 2020 decision and reconsider the case.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the NLRB did not abuse its discretion in vacating the 2020 decision due to the conflict of interest. The court also upheld the NLRB’s findings that Exxon refused to bargain in good faith on the supervisor PTO review issue and retaliated against the Union for past grievances. Additionally, the court supported the NLRB’s conclusion that Exxon unlawfully suggested employees would receive PPTO if they left the Union. The court denied Exxon’s petition for review and granted the NLRB’s cross-petition for enforcement of its order. View "ExxonMobil v. National Labor Relations Board" on Justia Law

Doctors Scott Sullivan and Frank DellaCroce, along with their associated business entities, entered into a turnkey agreement with Stewart Feldman and his associated entities to pool their risks through certain insurance arrangements. The agreement included an arbitration provision. The doctors later alleged that Feldman and his entities misled them about the insurance arrangements and failed to wind down the insurance entities upon request, leading to multiple arbitration proceedings.The United States District Court for the Southern District of Texas was involved in compelling and managing these arbitrations. The court initially allowed multiple arbitrations to proceed simultaneously and later confirmed four arbitration awards, despite their inconsistencies. The district court also issued a stay order to prevent further arbitrations until the existing ones were resolved.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the Glasser, Baker, and Kutcher arbitration awards, finding no grounds under the Federal Arbitration Act to vacate them. The court also affirmed in part the Jones arbitration award but reversed it in part concerning defendant Jeff Carlson, who was not bound by the arbitration agreement. The court vacated and remanded the district court’s order staying further arbitrations, allowing the parties to resolve the inconsistencies among the awards through additional arbitration if they choose. View "Sullivan v. Feldman" on Justia Law

Tracy Langiano alleged that he was shot and injured by Officer Landon Rollins in violation of the Fourth Amendment and that the City of Fort Worth’s policies contributed to this violation. Langiano was accused of sexually abusing his step-granddaughters and left his home after writing a suicide note. He checked into a motel with a loaded handgun, intending to kill himself. His son informed the police about the suicide note and the handgun. Police located Langiano at the motel, and Officer Rollins, without knocking, entered the room. Rollins claimed Langiano pointed a gun at him, prompting Rollins to shoot Langiano multiple times. Langiano disputed pointing the gun at Rollins but admitted holding it.The United States District Court for the Northern District of Texas denied Langiano’s motion to stay the civil suit while criminal charges were pending. The court granted summary judgment in favor of Officer Rollins and the City of Fort Worth, dismissing Langiano’s civil suit. Langiano appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the stay, as Langiano did not demonstrate substantial and irreparable prejudice. The court also affirmed the summary judgment in favor of Officer Rollins, finding that Rollins’ use of force was reasonable given the circumstances and that Langiano’s Fourth Amendment rights were not violated. Additionally, the court held that the warrantless entry into the motel room was justified due to the exigent circumstances of Langiano being armed and suicidal. The court also affirmed the summary judgment in favor of the City, as there was no constitutional violation to support a Monell claim. The district court’s judgment was affirmed. View "Langiano v. City of Fort Worth" on Justia Law

Kafi, Inc. ("Kafi") owns a residential property in League City, Texas, which it purchased from Joe and Kelly Richardson in September 2020. The Richardsons had financed the property with a loan from Sand Canyon Corporation in 2006, secured by an Adjustable Rate Note and a Deed of Trust. Sand Canyon transferred its interest in the loan to Wells Fargo Bank, N.A. ("Wells Fargo") in October 2006. Kafi challenged Wells Fargo's right to foreclose on the property, claiming the assignment of the Deed of Trust was forged. Kafi also sought equitable redemption, arguing it should be allowed to pay off any valid liens before foreclosure.The case was initially filed in Texas state court and then removed to the United States District Court for the Southern District of Texas. The district court dismissed Kafi's claims against Sand Canyon and Nationwide Title Clearing, Inc., and dismissed Kafi's standalone forgery claim and claim for exemplary damages. The court allowed Kafi's claims for declaratory relief, quiet title, and equitable redemption to proceed. Wells Fargo and PHH Mortgage Corporation filed a motion for summary judgment, which the district court granted, dismissing Kafi's remaining claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that Wells Fargo, as the holder of the Note, had standing to foreclose on the property under Texas law, regardless of the alleged forgery in the assignment of the Deed of Trust. The court also upheld the dismissal of Kafi's equitable redemption claim, noting that Kafi failed to provide sufficient evidence that it was ready, willing, and able to pay the redemption amount. The court emphasized that Kafi's declaration, which stated it was ready, able, or willing to redeem the property, was insufficient to meet the conjunctive requirement of being ready, willing, and able. Thus, the Fifth Circuit affirmed the district court's summary judgment in favor of Wells Fargo. View "Kafi, Inc. v. Wells Fargo Bank" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law