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

Cedric Ray Jones pleaded guilty to charges including conspiracy to commit Hobbs Act robbery and using and brandishing a firearm during a crime of violence. The conspiracy charge was the predicate for the firearm conviction under the residual clause of 18 U.S.C. § 924(c). Jones waived his rights to challenge his convictions and sentences on direct appeal or through collateral attack as part of his plea agreement. After the Supreme Court struck down the residual clause of § 924(c) in United States v. Davis, Jones sought to vacate his § 924(c) conviction under 28 U.S.C. § 2255, but the district court ruled that his collateral attack was barred by his appeal waiver.The United States District Court for the Northern District of Texas denied Jones's motion to dismiss the firearm counts and later denied his § 2255 motion, concluding that the appeal waiver was enforceable. The court granted a certificate of appealability on whether the waiver barred his Davis claim and whether it was unenforceable under the miscarriage of justice exception. Jones argued that the waiver should not apply because it was too broad, unknowing, and that enforcing it would result in a miscarriage of justice.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the appeal waiver was enforceable. The court rejected Jones's arguments, stating that the waiver was knowing and voluntary, and that the statutory-maximum exception did not apply. The court also declined to recognize a broad miscarriage-of-justice exception to the waiver. Consequently, the Fifth Circuit affirmed the district court's judgment, upholding the enforcement of the appeal waiver and denying Jones's request for relief based on the Davis decision. View "United States v. Jones" on Justia Law

Twin brothers Elijah and Kareem Muhammad were investigated for sex trafficking by the Fort Worth Police Department (FWPD) starting in 2018. Elijah was arrested in 2019 during a sting operation, and Kareem was arrested in 2023. The investigation revealed sex-trafficking activities dating back to 2011, involving multiple victims across several states. Concurrently, the FWPD and the Drug Enforcement Administration (DEA) were investigating the brothers for fentanyl trafficking. In 2023, Elijah and Kareem were arrested for drug-related offenses, leading to their guilty pleas for possession with intent to distribute fentanyl and unlawful possession of ammunition, respectively.The United States District Court for the Northern District of Texas handled the initial cases. Both brothers signed plea agreements in which the government promised not to bring additional charges based on the conduct underlying their guilty pleas. However, after their guilty pleas, the government charged them with sex trafficking in a separate case. The district court denied their motions to dismiss the sex-trafficking charges, finding that the sex-trafficking conduct was distinct from the drug-related offenses in terms of time, location, and statutory violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the sex-trafficking conduct was temporally, geographically, and statutorily distinct from the drug-related conduct. The court found that the sex-trafficking activities spanned over a decade and involved multiple states and victims, whereas the drug-related offenses were confined to a specific period and location. Consequently, the court concluded that the government did not breach the plea agreements by prosecuting the brothers for sex trafficking. The judgment of the district court was affirmed. View "United States v. Muhammad" on Justia Law

A bankruptcy trustee objected to the treatment of student-loan debt under two proposed Chapter 13 plans filed by Victoria Florita Durand-Day and Lavonda Latrece Evans. Durand-Day listed $113,560.65 in nonpriority unsecured claims, including two student loans totaling $54,195.00, but her plan only accounted for $71,580.65 in scheduled unsecured claims. Evans listed $106,402.00 in nonpriority unsecured claims, including twelve student loans totaling $73,927.00, but her plan only accounted for $32,475.00 in scheduled unsecured claims. Both debtors proposed to pay their student loans directly to the lenders rather than through the Chapter 13 trustee.The bankruptcy court overruled the trustee's objections and confirmed the plans, concluding that the plans satisfied 11 U.S.C. § 1325(b)(1)(A) because the student-loan obligations would be paid in full according to their contractual terms under § 1322(b)(5). The trustee appealed, and the district court affirmed the bankruptcy court's decision, holding that the payments toward the student-loan obligations were still "under the [Plans]" per § 1325(b)(1)(A) even if they continued beyond the end of the plans.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that the plans did not satisfy 11 U.S.C. § 1325(b)(1). The court held that "under the plan" means that all allowed, unsecured claims, including student-loan obligations, must be paid in full within the life of the Chapter 13 plan. The court vacated the confirmation of the plans and remanded the case for further proceedings, allowing the debtors to file new plans consistent with this decision. View "Bassel v. Durand-Day" on Justia Law

In 2018, a $200 million mixed-use development project at Louisiana State University experienced issues with its fire-protection sprinkler systems, which began to crack and leak. Allied World National Assurance Company, which paid over $10 million for system replacements, sued Nisus Corporation in 2021, alleging that Nisus falsely represented its product's compatibility with the pipe material, leading to the damage.The United States District Court for the Middle District of Louisiana granted summary judgment in favor of Nisus, concluding that Allied's claims were time-barred under Louisiana law. The court found that while Provident, the insured party, did not have actual or constructive knowledge of the cause of the damage, RISE Residential, Provident's agent, had constructive knowledge of the cause by November 2019. This knowledge was imputed to Provident, starting the prescription period.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that RISE Residential's constructive knowledge of the sprinkler system issues, which was imputed to Provident, triggered the running of the prescription period well before July 23, 2020. The court also found that Nisus did not prevent Allied from timely availing itself of its causes of action, as a reasonable inquiry by RISE Residential would have uncovered the necessary information. Therefore, Allied's claims were prescribed, and the summary judgment in favor of Nisus was affirmed. View "Allied World National v. Nisus" on Justia Law

8fig, Incorporated, a technology company, entered into agreements with several e-commerce merchants (Defendant-Appellants) to purchase projected revenue in exchange for an up-front payment. 8fig alleged that the Defendant-Appellants failed to remit the agreed payments and instead transferred the funds to a religious movement, World Olivet Assembly, closed their bank accounts, and went out of business. 8fig filed a lawsuit under 18 U.S.C. §§ 1964, 1962, and various state and common law claims. The parties filed a Joint Agreed Motion to Administratively Close and Seal Proceedings, which the district court granted, and the case settled quickly.Newsweek Digital, LLC moved to intervene and unseal the judicial record, arguing that the seal hindered its reporting. The district court granted Newsweek’s motion to intervene and unseal, allowing any party to propose redactions. Certain defendants filed proposed redactions, which the district court granted, and denied a motion to extend filing deadlines. The district court proceeding has been unsealed for over a year, except for documents with redacted versions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Newsweek had standing to intervene, as alleged violations of the public right to access judicial records and gather news are cognizable injuries-in-fact. The court found that the district court did not abuse its discretion in unsealing the records, emphasizing the public’s common law right of access to judicial records and the presumption in favor of transparency. The court affirmed the district court’s order granting Newsweek’s motion to intervene and unseal the proceeding. View "8Fig v. Stepup Funny" on Justia Law

William Dexter Lucas was involved in schemes to fraudulently obtain small-business loans from the government and vehicle loans from private institutions. He pleaded guilty to conspiracy to commit bank and wire fraud and waived his right to appeal. His presentence investigation report (PSR) included details of his fraudulent activities and mentioned allegedly fraudulent social security benefits he had been receiving. At sentencing, the district court ordered Lucas to pay restitution to both the private institutions and the Social Security Administration (SSA). Lucas appealed his sentence, challenging the restitution orders for the vehicle loans and social security benefits.The United States District Court for the Southern District of Texas initially handled the case. Lucas objected to the PSR's restitution calculations, arguing that the vehicle loans restitution was ordered to the wrong victim and incorrectly calculated, and that the social security benefits restitution was improper because he was entitled to the benefits and the alleged fraud was not part of the same scheme as the offenses in his indictment. The district court recalculated the vehicle loans restitution but upheld the SSA restitution, finding that Lucas's statement to the SSA was fraudulent and that the SSA fraud was part of the same conduct as the fraud alleged in the indictment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the SSA restitution was erroneous because the SSA fraud was not part of the same scheme or conspiracy as the offenses in the indictment. The court affirmed the vehicle loans restitution, finding that Lucas's challenge to the calculation was barred by his appeal waiver and that the dealerships were proper victims. The court affirmed the vehicle loans restitution but vacated the SSA restitution award. View "United States v. Lucas" on Justia Law

Julie Nevarez, on behalf of herself and her minor children, filed a lawsuit under 42 U.S.C. § 1983 against Louisiana State Police Troopers Justin Leonard and Anthony Dorris. The case stems from the fatal shooting of her husband, Miguel Nevarez, by officers from the Houma Police Department and the Terrebonne Parish Sheriff’s Office. Following the shooting, the Troopers obtained search warrants for the Nevarez home, the car Mr. Nevarez was in, and Mrs. Nevarez’s cell phone, claiming they were investigating an aggravated assault against a police officer by Mr. Nevarez. Mrs. Nevarez contended that this justification was pretextual and that the affidavits lacked probable cause.The United States District Court for the Eastern District of Louisiana denied the Troopers' third motion to dismiss, ruling that they were not entitled to qualified immunity. The court found that the plaintiffs plausibly alleged a claim under Malley v. Briggs, concluding that a reasonable officer would understand there was no probable cause to support the search warrants, given that Mr. Nevarez was deceased and the affidavits did not suggest others were involved or that the crime was ongoing.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that there was no clearly established law indicating that probable cause could not support a warrant to search for evidence of a crime that could not be prosecuted because the suspect had died. Consequently, the Troopers were entitled to qualified immunity. The case was remanded for further proceedings consistent with this opinion. View "Nevarez v. Dorris" on Justia Law

Dr. Blake Vanderlan, a physician at a hospital operated by Jackson HMA, LLC, alleged that the hospital systematically violated the Emergency Medical Treatment and Labor Act (EMTALA). He reported these violations to the Department of Health and Human Services, prompting an investigation by the Center for Medicare and Medicaid Services (CMS). CMS confirmed the violations and referred the matter to the Office of Inspector General (OIG) for potential civil monetary penalties. Vanderlan then filed a qui tam lawsuit under the False Claims Act (FCA) against Jackson HMA, alleging five FCA violations, including a retaliation claim.The United States District Court for the Southern District of Mississippi handled the case initially. The government investigated Vanderlan’s claims but declined to intervene. The case continued for six and a half years, during which the district court severed Vanderlan’s retaliation claims. The government eventually moved to dismiss the qui tam claims, arguing that the lawsuit interfered with administrative settlement negotiations and lacked merit. The district court granted the dismissal based on written filings and reaffirmed its decision after reconsideration.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not err in denying Vanderlan an evidentiary hearing, as the FCA only requires a hearing on the briefs. The court also determined that the government’s motion to dismiss fell under Rule 41(a)(1), which allows for dismissal without a court order, and thus, the district court had no discretion to deny the dismissal. The Fifth Circuit affirmed the district court’s judgment, concluding that the government’s decision to dismiss the case was justified and that the district court applied the correct standard. View "Vanderlan v. Jackson HMA" on Justia Law

A recently enacted Mississippi statute, House Bill 1126, aims to protect minors from harmful online material by requiring digital service providers (DSPs) to verify users' ages, obtain parental consent for minors, limit data collection, and implement strategies to mitigate harmful content exposure. NetChoice, L.L.C., a trade association for internet-focused companies, challenged the statute's constitutionality under the First and Fourteenth Amendments and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Southern District of Mississippi granted the preliminary injunction, finding that NetChoice was likely to succeed on its claims that the statute was unconstitutional. The court determined that NetChoice had associational standing to bring the suit on behalf of its members and that the statute imposed significant regulatory burdens that could cause financial harm. The Attorney General of Mississippi appealed, arguing that the district court erred in its findings and failed to perform the necessary facial analysis as mandated by the Supreme Court in Moody v. NetChoice, LLC.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court did not conduct the required two-step analysis outlined in Moody. This analysis involves defining the law's scope and determining which applications violate the First Amendment. The Fifth Circuit noted that the district court did not fully assess the range of activities and actors regulated by the statute or the specific regulatory burdens imposed on different DSPs. Consequently, the court vacated the preliminary injunction and remanded the case to the district court for further factual analysis consistent with the Supreme Court's opinion in Moody and Fifth Circuit precedent. View "NetChoice v. Fitch" on Justia Law

AT&T sought review of a Federal Communications Commission (FCC) forfeiture order, which fined the company $57 million for mishandling customer data in violation of section 222 of the Telecommunications Act. The FCC found that AT&T failed to protect customer proprietary network information (CPNI) and issued the fine after an internal adjudication process. AT&T argued that the FCC's in-house adjudication violated the Constitution by denying it an Article III decisionmaker and a jury trial.The FCC's Enforcement Bureau investigated AT&T following reports of misuse of customer location data by service providers. The Bureau issued a Notice of Apparent Liability for Forfeiture (NAL), proposing the penalty. AT&T responded in writing, contesting the penalty and raising constitutional challenges. The FCC rejected AT&T's arguments and affirmed the penalty, leading AT&T to pay the fine and seek review in the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit, guided by the Supreme Court's decision in SEC v. Jarkesy, agreed with AT&T that the FCC's enforcement procedures violated the Seventh Amendment and Article III. The court found that the FCC's imposition of civil penalties was akin to a common law action for money damages, which traditionally requires a jury trial. The court also determined that the public rights exception did not apply, as the action was closely related to common law negligence and did not fall within the historical categories of non-Article III adjudications.The court concluded that the FCC's process, which allowed for a section 504 trial only after the agency had already adjudicated the matter, did not satisfy the constitutional requirements. As a result, the Fifth Circuit granted AT&T's petition and vacated the FCC's forfeiture order. View "AT&T v. Federal Communications Commission" on Justia Law