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

David Wood was convicted of capital murder and sentenced to death in 1992 for the brutal murders of six females in 1987. The victims were found buried near El Paso, and evidence indicated that Wood had sexually assaulted them before killing them. Wood's conviction and sentence were affirmed by the Texas Court of Criminal Appeals (CCA). Over the years, Wood pursued extensive litigation in state and federal courts, including multiple motions for post-conviction DNA testing under Chapter 64 of the Texas Code of Criminal Procedure. The trial court granted some of his motions, but the results did not exonerate him. Subsequent motions were denied, and the CCA affirmed these denials, concluding that Wood had engaged in a pattern of piecemeal litigation and delay.Wood then filed a 42 U.S.C. § 1983 suit in the United States District Court for the Western District of Texas, alleging that the CCA's construction of Chapter 64 violated his procedural due process rights. He claimed that the CCA's consistent denial of DNA testing rendered the state-created testing right illusory and that the CCA's interpretation of the statute's unreasonable-delay provision was novel and unforeseeable. The district court dismissed Wood's complaint and denied his motion to stay his execution.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wood lacked standing for his first claim because a favorable ruling would not substantially likely lead to DNA testing. For his second claim, the court found it meritless, as the CCA's interpretation of the unreasonable-delay provision was neither novel nor unforeseeable. Consequently, the Fifth Circuit affirmed the district court's order and judgment and denied Wood's renewed motion to stay his execution. View "Wood v. Patton" on Justia Law

From 2009 to 2015, Clarence Roland engaged in a scheme to defraud mortgage lenders and title insurance companies by using aliases, fake businesses, and fraudulent documents. He promised homeowners facing foreclosure that he could help them eliminate their mortgages. Instead, he transferred property ownership to his shell entities, created fake mortgages, and sold the properties to unsuspecting buyers. Roland used fraudulent notary stamps and signatures to make these transactions appear legitimate.A jury in the United States District Court for the Southern District of Texas convicted Roland of conspiracy to commit wire fraud, wire fraud, and engaging in monetary transactions over $10,000 derived from unlawful activity. He was sentenced to ten years in prison, ordered to pay restitution of over $3 million, forfeit nearly $2 million, and assessed a $1,000 special assessment.The United States Court of Appeals for the Fifth Circuit reviewed Roland's appeal, where he raised several issues. He argued that the district court erred by admitting evidence of his and his co-conspirator’s prior convictions, limiting his good-faith defense, and denying his request for expert-witness funding. He also claimed that his conduct was not criminal and highlighted a clerical error regarding the special assessment.The Fifth Circuit found no reversible error in the district court's evidentiary rulings, determining that the admission of prior convictions was not plain error and that the limitations on Roland's good-faith defense were either appropriate or harmless. The court also upheld the denial of expert-witness funding, noting Roland's failure to make a formal request. The court agreed with Roland on the clerical error and modified the judgment to remove the $1,000 special assessment. In all other respects, Roland's conviction was affirmed. View "United States v. Roland" on Justia Law

In January 2023, law enforcement executed a search warrant at Juan David Cisneros's residence, resulting from a narcotics investigation. They found ammunition in his bedroom but no drugs or firearms attributable to him. Cisneros admitted to using the ammunition previously but claimed his mother-in-law purchased it. He was charged with possessing ammunition as a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Texas denied Cisneros's motion to dismiss the indictment, which argued that § 922(g)(1) was unconstitutional under the Second Amendment and exceeded Congress's power under the Commerce Clause. Cisneros pleaded guilty but reserved the right to appeal on Second Amendment grounds. The court adopted the Presentence Investigation Report, which included a four-level enhancement for possessing ammunition in connection with drug trafficking, and sentenced him to ninety-six months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Cisneros's facial challenge to § 922(g)(1) was foreclosed by precedent, and his as-applied challenge failed under plain error review. The court affirmed his conviction, finding no clear or obvious error in the application of § 922(g)(1) under the Second Amendment.However, the court found that the district court plainly erred in applying the sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing ammunition in connection with another felony offense. The court noted that there was no evidence the ammunition facilitated drug trafficking, as required by precedent. This error affected Cisneros's substantial rights, as it likely resulted in a longer sentence. Consequently, the Fifth Circuit vacated Cisneros's sentence and remanded for resentencing. View "United States v. Cisneros" on Justia Law

Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

Hector Flores, Jr. was sentenced to five years of probation under the Assimilative Crimes Act (ACA) for child endangerment, a state jail felony under Texas Penal Code § 22.041. The offense occurred on federal property, Big Bend National Park, where Flores placed his daughter in imminent danger by not providing food for four days in freezing temperatures. After violating his probation terms by testing positive for cocaine, the district court revoked his probation and resentenced him to two years of imprisonment followed by one year of supervised release.The United States District Court for the Western District of Texas initially sentenced Flores to probation. After he violated the terms of his probation, the court revoked his probation and imposed a new sentence of two years of imprisonment, the maximum allowed under Texas law for his offense, followed by one year of supervised release. Flores appealed, arguing that the additional one-year term of supervised release exceeded the maximum sentence authorized by Texas law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that under the ACA, a federal court may impose a term of supervised release in addition to the maximum term of imprisonment allowed by state law. The court reasoned that supervised release serves rehabilitative purposes distinct from imprisonment and does not extend the term of imprisonment. The court affirmed the district court's decision, concluding that the combined sentence of imprisonment and supervised release was permissible under federal law and consistent with the ACA's requirement for "like punishment." View "USA v. Flores" on Justia Law

In February 2020, Nicolas Robertson was shot and killed in Jackson, Mississippi. Two months later, Samuel Jennings, who was arrested for burglary and grand larceny, provided a statement to Detective Jacquelyn Thomas implicating Desmond Green in the murder. Green was subsequently indicted by a grand jury and detained for nearly two years. In March 2022, Jennings recanted his statement, admitting he was under the influence of drugs when he implicated Green and had no actual knowledge of the murder. Green was released from jail after the charges were dismissed.Green sued Detective Thomas under 42 U.S.C. § 1983, alleging violations of his Fourth and Fourteenth Amendment rights, including malicious prosecution and false arrest without probable cause. The United States District Court for the Southern District of Mississippi denied Detective Thomas qualified immunity at the motion-to-dismiss stage, allowing Green's claims to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Green sufficiently alleged violations of his clearly established Fourth Amendment right against false arrest and his Fourteenth Amendment due process rights. The court found that Detective Thomas allegedly manipulated a photo lineup and withheld exculpatory evidence from the grand jury, which could have influenced the grand jury's decision to indict Green. However, the court granted Detective Thomas qualified immunity on Green's malicious prosecution claim, as the constitutional tort of malicious prosecution was not clearly established in the Fifth Circuit at the time of Green's arrest.The Fifth Circuit affirmed the district court's denial of qualified immunity for Green's false arrest and due process claims but reversed the denial of qualified immunity for the malicious prosecution claim. View "Green v. Thomas" on Justia Law

Douglas Ramsey, the plaintiff, sued his former employer, Sheet Pile, L.L.C., for breach of his employment agreement and a promissory note under which he had loaned the company money. Sheet Pile counterclaimed for breach of the employment agreement and sought an injunction to force Ramsey to return confidential information. Ramsey largely succeeded at trial, receiving an award for prejudgment interest and the denial of Sheet Pile’s requested injunction. Sheet Pile appealed, challenging the jury instructions, sufficiency of the evidence, the grant of prejudgment interest, and the denial of injunctive relief.The United States District Court for the Western District of Texas oversaw the initial trial. The jury found in favor of Ramsey, awarding him the final $5,000 of his salary and $155,878.47 in damages on the loan. The jury also found that Ramsey breached the employment agreement but was not liable due to Sheet Pile’s prior material breach. After the trial, the district court awarded Ramsey prejudgment interest and denied Sheet Pile’s request for a permanent injunction. Sheet Pile filed a post-judgment motion reiterating its arguments, which the district court denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s decisions on the jury instructions and the finding of prior material breach. However, it vacated the award of prejudgment interest, finding that the jury had improperly included interest in its damages award, leading to a double recovery. The court remanded the case for the district court to offer a remittitur based on the amount owed on the loan as of the date Ramsey filed suit. The court also instructed the district court to consider an injunction requiring Ramsey to return any documents containing confidential information. The court affirmed in part, vacated in part, and remanded for further proceedings. View "Ramsey v. Sheet Pile" on Justia Law

Annette Rodriguez, the plaintiff, served as the Director of the City of Corpus Christi and Nueces County Public Health District. Her salary was split between the City and the County. In 2019, the City increased her salary to 90% of the market rate. During the COVID-19 pandemic, Rodriguez requested and initially received overtime pay, but the City later stopped these payments. Rodriguez faced several allegations of policy violations and creating a hostile work environment, leading to a disciplinary memorandum. Despite a positive evaluation from the County, the City terminated her in 2022 and hired a new director.Rodriguez sued the City in the United States District Court for the Southern District of Texas, claiming violations under the Equal Pay Act, Fair Labor Standards Act (FLSA), Title VII, and 42 U.S.C. § 1983. The district court dismissed her Section 1983 claim on the pleadings, finding she did not allege a constitutionally protected interest in continued employment. The court granted summary judgment to the City on the remaining claims, concluding Rodriguez was exempt from FLSA overtime pay requirements, did not establish the equal-work or equal-pay prongs of her EPA claim, and failed to identify a proper comparator for her Title VII claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's rulings, agreeing that Rodriguez did not engage in protected activity under the FLSA, failed to identify a proper comparator for her Title VII and EPA claims, and did not establish pretext for retaliation. The court also found that Rodriguez remained an exempt employee despite receiving additional overtime pay temporarily. The court concluded that the City paid Rodriguez on a salary basis, maintaining her exempt status under the FLSA. View "Rodriguez v. City of Corpus Christi" on Justia Law

Detective Jeff Scroggins of the Livingston Parish Sheriff’s Office suspected Quwinton Norman of supplying methamphetamine to Fleet Wallace, a narcotics distributor. Scroggins applied for search warrants for Norman’s apartment and a nearby house where Norman stayed after a drug transaction. The affidavit supporting the warrants included summaries of text messages between Norman and Wallace and observations of Norman’s activities. A Louisiana state court judge issued the warrants, and officers found drugs, cash, and other incriminating items in the house and Norman’s vehicle. Norman was indicted on federal charges of possession with intent to distribute methamphetamine and cocaine.Norman moved to suppress the evidence, arguing that the affidavit did not establish probable cause and was bare bones. The United States District Court for the Middle District of Louisiana held a hearing and granted the motion to suppress. The government appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s ruling, examining the good-faith exception to the exclusionary rule. The court determined that the good-faith exception applied because the affidavit was not bare bones. It contained specific facts and circumstances, such as text messages indicating drug transactions and observations of Norman’s movements, which allowed officers to reasonably believe there was a nexus between the house and evidence of drug trafficking. The court concluded that the state judge could draw reasonable inferences from the affidavit to determine probable cause. Therefore, the good-faith exception applied, and the court reversed the district court’s order excluding the evidence and remanded the case for further proceedings. View "United States v. Norman" on Justia Law