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

Scott Martin operated a business in Harris County, Texas, gathering contact information of criminal defendants from public court records and selling it to private attorneys. His business relied primarily on access to bail bond orders, which contained defendants’ addresses and other contact details. In June 2023, the then-presiding judge of the Harris County Criminal Courts at Law issued an administrative order instructing the district clerk to keep the contents of certain bond orders in misdemeanor cases confidential, making only the title, filing date, and page enumeration available to the public. This significantly reduced the information Martin could access, leading to substantial business losses. Martin unsuccessfully sought reconsideration of the order and then filed suit, asserting constitutional and statutory claims and seeking injunctive relief and damages.The case was heard by the United States District Court for the Southern District of Texas. The defendants, including the district clerk and judges, moved to dismiss, arguing the order did not violate any constitutional right and that they were immune from suit. The district court, after a hearing, granted the motion to dismiss. The court determined that under Los Angeles Police Department v. United Reporting Publishing Corp., Martin’s First Amendment claim failed because the order merely restricted access to government information, not speech. It also found no plausible claim under the Sixth Amendment or Texas law, and concluded Martin had no property interest in the information.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court affirmed the district court’s decision, holding that restricting access to the information in government possession does not violate the First Amendment, and Martin’s other constitutional and state law arguments lacked merit. The court also rejected Martin’s ultra vires claim, finding the judge acted within her statutory authority. Thus, the dismissal was affirmed. View "Martin v. Burgess" on Justia Law

In February 2019, Daryl Davis was stopped by Tyler Police Department officers as part of a drug sting. During the traffic stop, officers accused Davis of swallowing crack cocaine to destroy evidence, used force against him, and arrested him for tampering with evidence and interfering with public duties. Davis contended that the stop was pretextual, that he was falsely accused, subjected to excessive force, unlawfully detained, and that officers refused to order a drug test that would have disproven their accusation. He further alleged ongoing constitutional violations following his arrest, including malicious prosecution and unlawful searches and seizures during pretrial supervision, and claimed that city and county officials ignored his complaints to cover up broader unconstitutional policing.A magistrate judge in the United States District Court for the Eastern District of Texas screened Davis’s pro se complaint, found it untimely and lacking in sufficient factual allegations, and ordered him to amend. After Davis amended, the magistrate judge recommended dismissal for failure to state a claim, finding the claims time-barred under Texas’s two-year statute of limitations for § 1983 actions and insufficiently specific as to officials’ failure to act. The district court adopted this recommendation, dismissing the claims without prejudice except for those based on officials’ inaction, which were dismissed with prejudice. Davis appealed.The United States Court of Appeals for the Fifth Circuit affirmed the dismissal of Davis’s unlawful arrest, excessive force, and malicious prosecution claims, concluding they were time-barred or failed as a matter of law. The court also agreed that Davis had not sufficiently pleaded claims based on officials’ failure to act, but held those should have been dismissed without prejudice. The court vacated that portion of the judgment and remanded, directing the district court to allow Davis to amend his complaint and consider appointing counsel. The court expressed no opinion on the merits of any future pleadings. View "Davis v. Warren" on Justia Law

A group of parents and religious leaders in Texas, representing a diversity of religious beliefs, challenged the enactment of a Texas law (S.B. 10) requiring public elementary and secondary schools to display a large poster of the Ten Commandments in every classroom. The law specified the text, size, and location of the display, allowed for both private donations and district-purchased displays, and was set to go into effect in September 2025. The plaintiffs argued that being compelled to send their children to schools with such displays violated the Establishment Clause by effectively endorsing religion, and the Free Exercise Clause by undermining their rights to direct their children’s religious upbringing and coercing their children to honor or revere the Commandments.The case was originally heard in the United States District Court for the Western District of Texas. After a hearing, the district court denied the school districts’ motion to dismiss and granted a preliminary injunction, blocking enforcement of S.B. 10. The court held the law unconstitutional under both the Establishment Clause—applying the “secular purpose” prong from Stone v. Graham and Lemon v. Kurtzman—and the Free Exercise Clause, finding that the law likely coerced religious observance and interfered with parental rights. The court’s opinion was also influenced by a since-vacated Fifth Circuit panel decision in a related Louisiana case.On appeal, the United States Court of Appeals for the Fifth Circuit, sitting en banc, held that S.B. 10 did not violate either the Establishment or Free Exercise Clause. The court concluded that Stone and Lemon no longer apply; the proper inquiry is whether the law bears hallmarks of a founding-era religious establishment, such as compelled worship, religious taxes, or government control over doctrine. The court found S.B. 10 lacked these features and that mere display of religious text did not amount to unconstitutional coercion. The court reversed the district court’s judgment, vacated the injunction, and dismissed all claims. View "Nathan v. Alamo Heights ISD" on Justia Law

The case concerns events at a Starbucks location in La Quinta, California, where employees began a union organizing campaign in December 2021. Two shift supervisors, Andrea Hernandez and Jazmine Cardenas, actively supported the unionization effort. After the union won the election to represent employees, the union filed charges alleging Starbucks engaged in unlawful conduct during the organizing campaign. The National Labor Relations Board (NLRB) issued a complaint alleging that Starbucks had improperly restricted employees’ union discussions. To prepare its defense, Starbucks obtained Board-issued subpoenas directed to the two supervisors, seeking broad materials related to union activities.An administrative law judge (ALJ) found the subpoenas overbroad and granted petitions to revoke them, but allowed Starbucks to pursue narrower requests. The ALJ ultimately dismissed the underlying unfair labor practice complaint, with the NLRB affirming that decision. Separately, the Board initiated another unfair labor practice proceeding, alleging that Starbucks’ act of obtaining the subpoenas itself interfered with employees’ rights under Section 7 of the National Labor Relations Act. The ALJ concluded Starbucks’ subpoenas violated Section 8(a)(1), using the standard from National Telephone Directory Corp., which balances confidentiality interests against an employer’s need for information. The Board adopted this reasoning and ordered Starbucks to cease the conduct and post a notice.The United States Court of Appeals for the Fifth Circuit reviewed the case. The Fifth Circuit held that the Board applied the wrong legal standard by relying on National Telephone’s discovery rule, rather than the required “totality of the circumstances” test for coerciveness under Section 8(a)(1). The court vacated the Board’s order and remanded the case for further proceedings consistent with its opinion, clarifying that the proper inquiry is whether the employer’s conduct would tend to be coercive under all the circumstances. View "Starbucks v. NLRB" on Justia Law

Cuevas Machine Company entered into a subcontract with O’Neal Constructors for fabrication and machining work at a filtration plant owned by Calgon Carbon Corporation in Mississippi. Under the subcontract, Cuevas was to be paid after Calgon paid O’Neal. Despite nonpayment from O’Neal, Cuevas continued its work. In October 2023, Cuevas recorded two construction liens totaling over $1.2 million against Calgon’s property, but the lien documents did not explicitly state the last date labor, services, or materials were supplied—a statutory requirement. Instead, Cuevas attached invoices to the liens, which included dates, but it was unclear whether these dates satisfied the statutory requirement.After Cuevas filed suit to foreclose on the liens in Mississippi state court, Calgon removed the case to the United States District Court for the Southern District of Mississippi and moved to dismiss. The district court granted Calgon’s motion, dismissing Cuevas’s complaint with prejudice under Rule 12(b)(6). The district court concluded, making an Erie guess, that the liens were unenforceable because they did not clearly specify the required “last date” in the manner demanded by Mississippi law, and found that the attached invoices did not sufficiently cure this defect.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. Finding Mississippi law ambiguous on whether attachments that do not plainly state the “last date” can satisfy the statutory requirement, the Fifth Circuit certified the following question to the Mississippi Supreme Court: whether attaching invoices that do not explicitly state the “last date labor, services or materials were supplied” satisfies the requirement under Miss. Code Ann. § 85-7-405(1)(b) that a lien “specify the date the claim was due.” The Fifth Circuit did not decide the merits, instead certifying the question for authoritative resolution. View "Cuevas Machine v. Calgon Carbon" on Justia Law

The case concerns a search of Albert Alexander’s residence by Lafayette Police Department officers, who had a warrant to search for firearms. Upon executing the warrant, the officers found only pellet rifles, but also observed a large quantity of electronics and appliances—many in unopened boxes or wrapped—inside the house. These observations, combined with prior tips from Alexander’s granddaughter and her girlfriend that stolen goods were stored there, led the officers to seize the items on suspicion they were stolen. The seized property was not listed in the original search warrant.After being charged with possession of stolen property and later acquitted at trial, Alexander filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Louisiana. He alleged that the officers violated his Fourth Amendment rights by seizing items not listed in the warrant during the first search. The defendants moved for summary judgment, asserting qualified immunity. The district court granted summary judgment, finding that the officers’ seizure of the electronics and appliances was justified under the plain view doctrine, as their incriminating nature was immediately apparent given the circumstances and information available to the officers.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the officers did not violate the Fourth Amendment because, under the totality of the circumstances—including the tips received, officers’ observations, and their experience—the officers had probable cause to believe the items were stolen, satisfying the plain view exception. The court affirmed the district court’s grant of summary judgment, holding that the officers were entitled to qualified immunity. View "Alexander v. Arceneaux" on Justia Law

Several individuals, all enthusiasts of distilling spirits, and a non-profit organization devoted to legalizing at-home hobby distilling, sought to challenge longstanding federal laws prohibiting the operation of home distilleries. The plaintiffs, who had experience with lawful alcohol production for fuel or other beverages, expressed clear intent to distill spirits for personal consumption at or near their residences. They faced explicit warnings from federal authorities that such activity was illegal and punishable by substantial penalties, and that no permits would be issued for home-based distillation of consumable spirits.After contacting the Alcohol and Tobacco Tax and Trade Bureau (TTB) and receiving confirmation that home distilling would not be permitted, the plaintiffs filed suit in the United States District Court for the Northern District of Texas against the TTB and the U.S. Department of Justice. The district court dismissed several individual plaintiffs for lack of standing but allowed the claims of one individual and the non-profit organization to proceed. On the merits, the district court determined that federal statutes barring home distilling for beverage purposes violated the Constitution’s Commerce, Taxation, and Necessary and Proper clauses. The government appealed, and the dismissed plaintiffs cross-appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that all individual plaintiffs and the non-profit organization had standing to sue. On the merits, the Fifth Circuit ruled that the statutory prohibition on home distilleries and associated criminal penalties exceeded Congress’s constitutional authority under both the Taxation Clause and the Necessary and Proper Clause, as the prohibitions were not “plainly adapted” to raising revenue and represented an improper federal intrusion into matters reserved to the states. The Fifth Circuit affirmed the district court’s judgment and injunction against enforcement of the statutes, as modified. View "McNutt v. Dept of Justice" on Justia Law

Branch Metrics, Inc. brought an antitrust action against Google, LLC, alleging violations of the Sherman Act based on documents uncovered in earlier litigation brought by the United States against Google. Branch Metrics claimed Google maintained monopoly power in online search and search advertising markets, using exclusive agreements that caused anticompetitive harm. The suit was filed in the Eastern District of Texas, although most relevant witnesses and evidence were located in California.Google responded by requesting a transfer of venue to the Northern District of California under 28 U.S.C. § 1404(a), arguing that it was clearly more convenient for parties and witnesses and that the sources of proof were located there. The United States District Court for the Eastern District of Texas permitted venue discovery but ultimately denied Google’s motion to transfer. The court found that certain private interest factors slightly favored transfer, while one public interest factor—administrative difficulties stemming from court congestion—weighed against transfer, and the rest of the factors were neutral.On mandamus review, the United States Court of Appeals for the Fifth Circuit found that the district court misapplied the law by placing undue weight on the court congestion factor, which Fifth Circuit precedent considers speculative and non-dispositive. The appellate court held that the district court erred by allowing that single factor to override all other factors, contrary to circuit authority. The Fifth Circuit also rejected Branch Metrics’ argument that the Clayton Act insulated its choice of venue from transfer. The court granted Google’s petition for a writ of mandamus and ordered the case transferred to the Northern District of California. View "In Re: Google" on Justia Law

Porch.com is the parent company of Homeowners of America Insurance Company (HOA), which entered into an agreement with Gallagher Reinsurance (Gallagher) to serve as its reinsurance broker. Gallagher brokered a reinsurance deal for HOA involving Whiterock as the insurer and Vesttoo as a financier, with the understanding that China Construction Bank (CCB) would provide a letter of credit as collateral. Instead, HOA was only given a letter from Yu Po Finance stating a letter of credit would be forthcoming, which was never issued. Gallagher continued to assure HOA that the collateral was valid, leading HOA to authorize a substantial withdrawal by Vesttoo. When it was later revealed that Vesttoo’s collateral was invalid and CCB had never issued the promised letter of credit, HOA suffered financial harm, including increased costs for replacement reinsurance and regulatory intervention.The United States District Court for the Northern District of Texas heard Porch’s breach-of-contract claims against Gallagher, alleging violations of several sections of their agreement. The district court dismissed all of Porch’s claims with prejudice, finding that Gallagher did not breach the contract and that amending the complaint would be futile.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The Fifth Circuit affirmed the dismissal of Porch’s claims under Sections 5 and 11 of the contract, concluding Gallagher had no duty to procure collateral documents from CCB or to comply with Texas insurance laws under the economic sanctions provision. However, the Fifth Circuit reversed the dismissal of Porch’s claim under Section 13, finding that Porch plausibly alleged Gallagher failed to perform administrative services customarily expected of a reinsurance broker after contract placement. The case was remanded for further proceedings on the Section 13 claim. View "Porch.com v. Gallagher Re" on Justia Law

Law enforcement officers executed a search warrant at a residence in Starkville, Mississippi, after an officer obtained the warrant through an affidavit detailing three controlled drug purchases involving a confidential informant. The affidavit described the procedures followed during the buys, including continuous surveillance of the informant and searches for contraband before and after each transaction. The search resulted in the seizure of drugs, firearms, money, and cellphones, and the resident was arrested. During a subsequent police interview, the resident was read his Miranda rights and signed a form acknowledging this, but the waiver portion of the form was not read aloud or explained.The United States District Court for the Northern District of Mississippi granted the defendant’s motion to suppress both the physical evidence from the search and the statements made during the interview. The district court found the supporting affidavit for the search warrant to be “bare bones,” lacking sufficient detail or corroboration, and concluded that the officer’s reliance on the warrant was not objectively reasonable. The court further found that the defendant’s signature on the Miranda form did not amount to a voluntary waiver of his rights, as the waiver section was not explained and the officer’s conduct was considered deceptive.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision. The appellate court held that the good-faith exception to the exclusionary rule applied because the affidavit was not “wholly conclusory” and contained sufficient factual detail to justify an officer’s reasonable reliance on the warrant. Thus, the suppression of the physical evidence was reversed. Regarding the statements, the appellate court agreed that the express waiver was involuntary but remanded for the district court to determine whether an implied waiver occurred under the totality of the circumstances. The panel retained jurisdiction pending the district court’s further findings. View "USA v. Weaver" on Justia Law