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

Brent Dubois was convicted in 2011 of possession of a controlled substance with intent to distribute, receiving a sentence of 188 months in prison and three years of supervised release. As part of his supervised release, a condition required him to participate in a substance abuse program, allowing the probation office to decide whether that would be inpatient or outpatient treatment. After a relevant amendment to the Sentencing Guidelines, Dubois’s sentence was reduced to 151 months. Upon completing his incarceration in 2023, Dubois began supervised release, but struggled to comply with outpatient treatment requirements. After repeated difficulties and four revocation hearings, his probation officer filed a petition for revocation, leading Dubois to admit to violations except one allegation, which the government withdrew.The United States District Court for the Northern District of Texas sentenced Dubois to ten months in prison and 32 months of supervised release, reimposing the original supervised release conditions. Notably, it again permitted the probation office to determine whether Dubois’s substance abuse treatment would be inpatient or outpatient. Dubois did not object to this condition at sentencing, but later appealed, arguing that the delegation of this decision to the probation office was improper.The United States Court of Appeals for the Fifth Circuit reviewed the case under the plain error standard, given Dubois’s lack of objection in district court. The Fifth Circuit held that permitting the probation office to decide between inpatient and outpatient treatment constituted an impermissible delegation of the district court’s core judicial sentencing function, particularly since the sentence following revocation was only ten months. The court found this error to be clear under existing precedent, affected Dubois’s substantial rights, and warranted discretionary correction. The Fifth Circuit vacated the supervised release condition at issue and remanded the case for further proceedings. View "United States v. Dubois" on Justia Law

Endure Industries, Inc., a seller of disposable medical supplies, sought to participate as a supplier in Vizient’s group purchasing organization (GPO), which negotiates bulk purchasing contracts for healthcare providers. Vizient is the largest GPO in the United States, serving a majority of general acute care centers and academic medical centers. After Vizient rejected Endure’s bid to supply medical tape in favor of another supplier, Endure filed an antitrust suit against Vizient and related entities, alleging monopolization and anticompetitive conduct in two proposed markets for disposable medical supplies.The United States District Court for the Northern District of Texas granted summary judgment to Vizient, finding that Endure failed to define a legally sufficient relevant market under antitrust law. The district court reasoned that Endure’s expert’s market definitions—(1) the sale of disposable medical supplies through GPOs to acute care centers, and (2) sales to Vizient member hospitals—excluded significant alternative sources of supply. Specifically, evidence showed that many hospitals purchase substantial amounts of supplies outside GPO contracts, demonstrating that reasonable substitutes exist and undermining Endure’s theory of market foreclosure.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed only the issue of market definition. The Fifth Circuit held that Endure did not raise a genuine dispute of material fact regarding its proposed markets, as its definitions failed to account for all commodities reasonably interchangeable by consumers. The court found that significant hospital purchasing occurs outside GPOs and that Vizient members are not “locked in” to buying exclusively through Vizient. The Fifth Circuit affirmed the district court’s summary judgment in favor of Vizient, concluding that neither of Endure’s proposed antitrust markets was legally sufficient. View "Endure Industries v. Vizient" on Justia Law

Two individuals, Vetter and Smith, co-wrote the song “Double Shot (Of My Baby’s Love)” in 1962 and assigned all copyright interests to Windsong Music Publishers in 1963, including a contingent assignment of renewal rights. After Smith died in 1972, his heirs and Vetter renewed the copyright when the original term ended in 1994. Windsong’s ownership of renewal rights depended on the authors’ survival; thus, Windsong received Vetter’s renewal rights because he survived, while Smith’s heirs received his share. Vetter Communications Corporation later purchased Smith’s heirs’ renewal rights. In 2019, Vetter terminated his earlier assignment under 17 U.S.C. § 304(c), aiming to recapture his rights. The publisher’s ownership interests were subsequently sold to Resnik Music Group. When licensing negotiations arose for international use, conflicting ownership claims led Vetter and his corporation to seek a declaratory judgment establishing their sole copyright ownership worldwide.The United States District Court for the Middle District of Louisiana denied Resnik’s motion to dismiss and granted summary judgment for the plaintiffs. The court declared that Vetter was the sole owner of the recaptured copyright interest globally, and Vetter Communications Corporation was the sole owner of the renewal copyright interest globally, establishing their exclusive ownership.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment de novo. The Fifth Circuit affirmed the district court’s judgment, holding that termination of copyright assignments under 17 U.S.C. § 304(c) and the renewal provisions of the Copyright Act of 1909 confer worldwide ownership rights to the terminating author or their heirs, not limited to domestic rights. The court found that statutory text, context, and purpose support this interpretation, and that the judgment does not conflict with international treaty obligations or relevant legal principles. View "Vetter v. Resnik" on Justia Law

Ayodeji Awe, a former chaplain at Harris Health System (HHS), alleged that he and other minority chaplains were underpaid during his tenure. After leaving HHS in 2020, Awe reapplied for a chaplain position in 2021 but was not rehired; HHS instead selected three other candidates. Awe believed the failure to rehire him was due to age discrimination and retaliation for his prior complaints about workplace issues, including underpayment of minority chaplains.Following receipt of a right-to-sue letter from the Equal Employment Opportunity Commission in June 2022, Awe filed suit in the United States District Court for the Southern District of Texas, asserting claims under the Age Discrimination in Employment Act (ADEA) and Title VII of the Civil Rights Act. The district court granted summary judgment for HHS on all claims, finding that Awe did not rebut HHS’s nondiscriminatory reasons for its hiring decisions. Specifically, the district court ruled that Awe failed to make a prima facie case on his ADEA claims and did not present sufficient evidence of pretext for his Title VII retaliation claim.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed. The Fifth Circuit held that Awe did not establish a prima facie case of age discrimination, as one of the hired candidates was older than Awe, and another only five years younger. For ADEA retaliation, the court found Awe did not show his complaints were age-related. Although Awe established a prima facie Title VII retaliation claim, he failed to show that HHS’s stated preference for internal candidates was pretextual, nor that he was clearly better qualified than those hired. The Fifth Circuit affirmed the district court’s judgment. View "Awe v. Harris Health" on Justia Law

Margaret Woods, proceeding without an attorney, sued her former employer STS Services, L.L.C., after being terminated from her job. In her Third Amended Complaint, Woods alleged that she was fired because she is a black woman and replaced by white men. Earlier versions of her complaint included claims for breach of contract and race discrimination under 42 U.S.C. § 1981, which she abandoned, leaving only claims of race and sex discrimination under Title VII. Woods did not provide factual details about her qualifications for the position from which she was terminated.The United States District Court for the Northern District of Texas reviewed Woods’s successive complaints. Each time, the district court dismissed her complaints for failure to state a claim but allowed her opportunities to amend and refile. Woods submitted her Second Amended Complaint late, which was also dismissed. Her Third Amended Complaint was timely, but again found deficient for failing to plead facts regarding her qualifications. The court gave her another chance to amend, but Woods did not file a Fourth Amended Complaint within the deadline, or at all. The district court ultimately dismissed the case with prejudice and entered judgment in favor of STS Services, assessing costs against Woods.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The appellate court held that Woods failed to state a Title VII claim because her complaint did not include sufficient factual allegations to establish that she was qualified for her position, a necessary element of a prima facie case under Title VII. The Fifth Circuit also found that the district court did not abuse its discretion in dismissing Woods’s complaint with prejudice after repeated deficiencies and failures to amend. The judgment of the district court was affirmed. View "Woods v. STS Services" on Justia Law

Wilson and two associates attempted to purchase a firearm from D.J. at a gas station, only to discover that the firearm was fake. In retaliation, Wilson retrieved a handgun modified with a machinegun conversion device and an extended magazine from his vehicle. He confronted D.J. and fired multiple rounds, fatally wounding him. Wilson and his companions then robbed D.J. and fled the scene. Police subsequently located Wilson, who confessed to the shooting and acknowledged the weapon was equipped with a machinegun conversion device.Wilson was charged in the United States District Court for the Northern District of Texas with unlawful possession of a machinegun under 18 U.S.C. § 922(o). He moved to dismiss the indictment, arguing that § 922(o) violated the Second Amendment, but the district court denied the motion. Wilson pleaded guilty without a written plea agreement. At sentencing, the Presentence Investigation Report applied the Sentencing Guidelines cross-reference to second-degree murder due to the death resulting from Wilson's conduct, resulting in a recommended sentence of 120 months, the statutory maximum. Wilson objected, claiming the cross-reference failed to account for his self-defense claim, but the district court overruled his objection, adopted the PSR, and imposed the recommended sentence.The United States Court of Appeals for the Fifth Circuit reviewed Wilson’s appeal. He challenged his conviction on Second Amendment grounds and the application of the second-degree murder cross-reference during sentencing. The Fifth Circuit held that circuit precedent, specifically Hollis v. Lynch, forecloses any Second Amendment protection for machineguns, and that Supreme Court precedent in New York State Rifle & Pistol Association, Inc. v. Bruen does not overrule this holding. The court also found no plain error in the district court’s application of the second-degree murder cross-reference. The Fifth Circuit affirmed the district court’s judgment. View "United States v. Wilson" on Justia Law

The defendant repeatedly contacted a 13-year-old girl, H.H., via Snapchat, demanding nude photographs and videos of explicit acts. He threatened to expose her, specified the exact nature and timing of the images he wanted, and coerced her compliance by threatening to inform her mother when she refused or delayed. On one occasion, he met H.H. in person, where he engaged in sexual intercourse with her despite knowing her age. Electronic evidence later revealed that the defendant had engaged in similar conduct with at least ten other female victims aged 12 to 16. He was charged with one count of coercion and enticement of a minor to engage in sexual activity and pleaded guilty.In the United States District Court for the Western District of Texas, the Presentence Report (PSR) recommended a two-level sentencing enhancement for distribution of material involving the sexual exploitation of a minor under U.S.S.G. § 2G2.1(b)(3). The defendant objected to this enhancement, arguing that his conduct amounted to “mere solicitation” rather than distribution, as he had not transferred the images to others. The probation officer and the district court disagreed, finding that the defendant’s coercive actions in inducing the victim to produce and send child pornography constituted distribution as contemplated by the guideline. The district court overruled the objection, adopted the PSR, and sentenced the defendant to life imprisonment.The United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in applying the distribution enhancement. The Fifth Circuit held that the enhancement was appropriate because the defendant exercised significant control over the victim and actively participated in the distribution by coercing and directing the production and delivery of child sexual abuse material. The court distinguished “mere solicitation” from the defendant’s conduct and affirmed the district court’s judgment. View "USA v. Lowe" on Justia Law

The case concerns an individual who was convicted in Texas state court in 2021 for sexually assaulting a thirteen-year-old child. After serving his sentence, he was deported to Honduras due to his lack of lawful immigration status. He later reentered the United States illegally and, following his detention for immigration violations in 2024, admitted that he had not registered as a sex offender, as required by federal law. He pleaded guilty in federal district court to failing to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA).The United States District Court for the Southern District of Texas classified the defendant as a tier III sex offender—the most serious category under SORNA—and sentenced him to 24 months’ imprisonment followed by five years of supervised release. This classification was based on the court’s determination that his Texas conviction was comparable to the federal offenses of aggravated sexual abuse or sexual abuse. The defendant did not object to the presentence report’s findings at sentencing but appealed, arguing that he should have been classified as a tier I offender, the least severe category.The United States Court of Appeals for the Fifth Circuit reviewed the appeal for plain error, as the argument was raised for the first time on appeal. The court concluded that the Texas statute under which the defendant was convicted criminalizes a broader range of conduct than the comparable federal offenses referenced by SORNA for tier II and tier III classification. Specifically, the Texas law punishes consensual sexual acts with minors under 17, while the federal statutes require nonconsensual conduct or involve narrower age ranges. Therefore, the Fifth Circuit held that the defendant does not qualify as either a tier II or tier III offender and must be classified as a tier I offender. The court vacated the sentence and remanded for resentencing. View "United States v. Quintanilla-Matamoros" on Justia Law

Police officers in Rosenberg, Texas conducted a high-risk stop of a white Dodge Charger matching the description of a vehicle involved in a report of armed suspects. The only occupants were Michael Lewis and Regina Armstead, an elderly couple. Lewis had a dialysis-related stent in his left forearm, which could be damaged by placing handcuffs on that arm. During the stop, Lewis was handcuffed for about six minutes, reportedly experiencing pain. He later discovered his stent had been damaged and required surgery. Armstead informed an officer that Lewis was a dialysis patient, and Lewis claimed he told officers about his condition both before and after being handcuffed, though his statements were inconsistent.Lewis and Armstead filed suit in the United States District Court for the Southern District of Texas against the City, the police department, and the officers, including an excessive force claim. After a magistrate judge’s recommendation, the district court granted qualified immunity on most claims but denied it on Lewis’s excessive force claim against the five officers, finding a genuine dispute of material fact as to when the officers were informed about Lewis’s medical condition. The officers appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of qualified immunity de novo. The Fifth Circuit held that the officers did not violate any clearly established law by briefly handcuffing Lewis during a high-risk stop, regardless of whether they had advance notice of his medical condition. The court found that relevant precedent did not place the constitutional question beyond debate under the circumstances, and thus, the officers were entitled to qualified immunity. The Fifth Circuit reversed the district court’s denial of qualified immunity. View "Lewis v. Delgado" on Justia Law

Tony Lee Johnson, a convicted felon on supervised release, was arrested by law enforcement officers after he violated his release conditions by failing drug tests. The arrest was executed at Johnson’s residence when he and his girlfriend, Beatrice Simmons, were found in his vehicle. After Johnson was removed and arrested, Simmons was temporarily detained but not handcuffed. Officer Pringle, suspecting Johnson might be hiding something, conducted a warrantless search of the vehicle's driver area and center console, discovering a loaded handgun. Simmons stated she was unaware of the firearm and confirmed she was on parole for a prior drug offense.The United States District Court for the Northern District of Texas held a hearing on Johnson’s motion to suppress the handgun, which he argued was seized in violation of his Fourth Amendment rights. The district court denied the motion, finding the search constitutional under the protective-sweep exception outlined in Michigan v. Long, reasoning that Simmons posed a potential threat to officer safety due to her criminal history, relationship with Johnson, and emotional proximity to the arrest. Johnson then entered a conditional guilty plea, reserving his right to appeal the denial of the suppression motion, which led to his appeal to the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the warrantless search was not justified under the protective-sweep exception because no specific, articulable, contemporaneous facts suggested Simmons was potentially dangerous or would access a weapon. The court reversed the district court’s denial of the suppression motion and vacated Johnson’s conviction and sentence. View "United States v. Johnson" on Justia Law