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

Trinity Energy Services, L.L.C. ("Trinity Energy") and Southeast Directional Drilling, L.L.C. ("Southeast Drilling") were involved in a subcontract for constructing natural gas pipelines. Disputes arose over liability for "stand-by costs" incurred during construction delays. The parties agreed to arbitration, where a panel awarded Southeast Drilling $1,662,000 in stand-by costs from Trinity Energy. Trinity Energy petitioned to vacate the arbitration award, but the district court denied the petition and confirmed the award. Trinity Energy then appealed.The United States District Court for the Northern District of Texas initially denied Trinity Energy's petition to vacate the arbitration award and granted Southeast Drilling's motion to confirm it. Trinity Energy appealed this decision, but the appeal was dismissed as interlocutory by the United States Court of Appeals for the Fifth Circuit. Subsequently, the district court granted Southeast Drilling's cross-motion to confirm the arbitration award, leading to Trinity Energy's timely appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court's order de novo and emphasized the narrow and deferential standard of review for arbitration awards. The court found that the arbitration panel had construed the subcontract and based its decision on its terms, thus not exceeding its authority under 9 U.S.C. § 10(a)(4). The court also rejected Trinity Energy's argument that the panel manifestly disregarded Texas law, noting that "manifest disregard of the law" is not a valid ground for vacatur under the Federal Arbitration Act. Consequently, the Fifth Circuit affirmed the district court's judgment confirming the arbitration award. Southeast Drilling's request for sanctions against Trinity Energy was denied due to procedural deficiencies. View "Trinity Energy Services v. SE Directional Drilling" on Justia Law

Ryan Rose, an electrical technician, sued Nissan North America, Inc. after suffering an electric shock while working at Nissan’s plant in Canton, Mississippi. Rose was employed by Automated Power, Inc., an electrical engineering firm hired by Nissan to repair damaged equipment following an electrical fault. Rose was injured while working in the plant’s A-B tiebreaker cubicle, which he believed was de-energized. However, the cubicle was still energized on one side, leading to his injury.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of Nissan. The court found that Automated Power was an independent contractor and that both Automated Power and Rose knew or should have known about the dangers associated with the work. Under Mississippi law, a premises owner is not liable for injuries to an independent contractor or its employees resulting from known dangers.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Automated Power was indeed an independent contractor and that the company and Rose were aware of the potential dangers. The court concluded that Mississippi Code § 11-1-66 shielded Nissan from liability, as the statute exempts premises owners from liability for injuries to independent contractors or their employees resulting from known dangers. The court found no genuine dispute of material fact regarding Automated Power’s knowledge of the danger, thus affirming the summary judgment in favor of Nissan. View "Rose v. Nissan North America" on Justia Law

Defendants Louis Age Jr., Louis Age III, Stanton Guillory, and Ronald Wilson were convicted and sentenced to life imprisonment for their roles in the murder-for-hire of Milton Womack, a federal witness in a healthcare fraud case. The defendants raised ten issues on appeal, including challenges to the sufficiency of the evidence, the admission of certain evidence, and the jury selection process.The United States District Court for the Eastern District of Louisiana convicted the defendants on multiple counts, including conspiracy to commit murder-for-hire, murder-for-hire, conspiracy to tamper with a federal witness, and witness tampering. The district court sentenced each defendant to at least one term of life imprisonment. The defendants appealed their convictions and sentences, arguing that the evidence was insufficient to support their convictions and that the district court made several errors in admitting evidence and instructing the jury.The United States Court of Appeals for the Fifth Circuit reviewed the case and found no error in the district court's rulings. The court held that the evidence presented at trial was sufficient to support the defendants' convictions. The court also found that the district court did not abuse its discretion in admitting evidence related to the defendants' prior criminal activities and in denying the defendants' motions to sever their trials. Additionally, the court held that the district court did not err in its jury instructions or in its handling of the jury selection process.The Fifth Circuit affirmed the district court's judgment, upholding the defendants' convictions and sentences. The court concluded that the defendants' arguments on appeal were unpersuasive and that the district court had acted within its discretion in its rulings. View "United States v. Age" on Justia Law

Mark Eugene Ricks, a Texas state prisoner, filed a pro se lawsuit under 42 U.S.C. § 1983 against employees of the University of Texas Medical Branch (UTMB), alleging violations of his Eighth Amendment rights. Ricks claimed that he was denied treatment for chronic hepatitis C virus (HCV) based on nonmedical reasons and that the TDCJ HCV Policy was the driving force behind this unconstitutional denial of treatment. He sought injunctive and declaratory relief, as well as damages.The United States District Court for the Southern District of Texas granted the defendants' motion to dismiss Ricks's complaint for failure to state a claim, concluding that his allegations did not support a claim for deliberate indifference. The district court also denied Ricks's motion for appointment of counsel. Ricks filed a timely appeal, and the district court denied him leave to proceed in forma pauperis (IFP) on appeal, certifying that any appeal would not be taken in good faith.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and found that the district court erred in dismissing Ricks's complaint without allowing him an opportunity to amend his pleadings. The appellate court held that Ricks's allegations, when liberally construed, could potentially raise a viable claim of deliberate indifference. The court also found that the district court abused its discretion in denying Ricks's motion for appointment of counsel without considering the relevant factors set out in Ulmer v. Chancellor.The Fifth Circuit vacated the district court's orders granting the motion to dismiss and denying the appointment of counsel. The case was remanded with instructions for the district court to allow Ricks to amend his pleadings and to appoint counsel to represent him. View "Ricks v. Khan" on Justia Law

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