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

A mortgage issuer, Reverse Mortgage Funding, LLC (RMF), participated in a federal program allowing it to securitize reverse mortgages. When RMF entered bankruptcy, Texas Capital Bank provided debtor-in-possession financing, secured by RMF’s interests in certain collateral, specifically incremental balances on the mortgages known as “tails.” After RMF defaulted on its agreement, the Government National Mortgage Association (Ginnie Mae), under its statutory and contractual authority, extinguished RMF’s interests in the underlying mortgages and assumed ownership of the loans, also extinguishing Texas Capital’s lien interest in the mortgage tails. Texas Capital argued that Ginnie Mae’s actions violated federal law and Texas tort law.The United States District Court for the Northern District of Texas initially allowed Texas Capital’s claims for statutory authority under the Administrative Procedure Act (APA) and tortious interference to proceed, but dismissed the promissory estoppel claim due to sovereign immunity. Later, the district court granted summary judgment to Ginnie Mae, finding it acted within its statutory authority and concluding that the extinguishment of RMF’s interests necessarily eliminated Texas Capital’s derivative interest in the mortgage tails. The court also dismissed Texas Capital’s tortious interference claim, citing sovereign immunity and a lack of legal basis, and refused to consider Texas Capital’s arbitrary-and-capricious APA theory because it was not sufficiently pled.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. It held that Ginnie Mae acted within its statutory and contractual authority under 12 U.S.C. § 1721(g)(1) in extinguishing both RMF’s and Texas Capital’s interests in the mortgages. The court affirmed the district court’s summary judgment, finding Texas Capital’s tortious interference claim barred by sovereign immunity and ruling that Texas Capital’s failure to plead an arbitrary-and-capricious APA theory justified the district court’s refusal to consider it. The judgment of the district court was affirmed. View "Texas Captl Bank v. Govt Natl Mtge" on Justia Law

A federal prisoner, sentenced in August 2020 for enticement of a minor, spent approximately ten months in various facilities before arriving at his designated Bureau of Prisons (BOP) institution in June 2021. He filed a pro se habeas petition under 28 U.S.C. § 2241, arguing that under the First Step Act (FSA), he was entitled to earn time credits for the period between his sentencing and his arrival at the designated facility. He claimed these credits should count toward his eligibility for home confinement and that the BOP was required to recognize his calculation of credits, leading to an earlier projected transfer date.The United States District Court for the Western District of Texas dismissed his petition. The court found that, under the FSA and relevant BOP regulations, the prisoner was not eligible to earn credits before arrival at his designated BOP facility. The court also held it lacked authority to order the BOP to place him in home confinement or otherwise direct his placement.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The Fifth Circuit affirmed the district court’s decision. The court held that, regardless of any debate over when FSA credit earning may begin, the petitioner failed to show any participation—or even attempted participation—in recidivism reduction programs or productive activities during the period in question. Participation is a statutory prerequisite for earning such credits under the FSA. The court further held that only the BOP has the authority to designate a prisoner’s place of confinement, and the courts cannot review such decisions. Allegations of judicial bias were found to be conclusory and did not meet the standard for plain error. Accordingly, the judgment was affirmed. View "Hogan v. FCI, La Tuna Case Mgr" on Justia Law

MIECO, L.L.C., an energy trading firm, entered into a contract with Pioneer Natural Resources USA, Inc. to purchase a specified quantity of natural gas daily on a Firm basis from November 2020 to March 2021. The contract included a force majeure clause excusing performance for certain uncontrollable events. In February 2021, Winter Storm Uri struck Texas, causing severe weather that disrupted natural gas production and delivery. Pioneer failed to deliver the contracted amount from February 14 to 19 and issued a force majeure notice. MIECO purchased replacement gas at higher prices and later sued Pioneer for breach of contract, seeking over $9 million in damages. Pioneer admitted nonperformance but argued it was excused by the force majeure provision.The United States District Court for the Northern District of Texas initially granted summary judgment in favor of Pioneer, finding the storm was a force majeure event and Pioneer had exercised due diligence. MIECO appealed, and the United States Court of Appeals for the Fifth Circuit reversed, holding that genuine disputes of material fact remained regarding whether Pioneer’s performance was truly prevented and if Pioneer exercised reasonable efforts and due diligence. The Fifth Circuit remanded the case for a bench trial. After the trial, the district court again found for Pioneer, determining the storm prevented performance and Pioneer had made reasonable efforts both before and after the storm to mitigate its impacts.Upon appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal issues de novo. The court held that the district court complied with its mandate, properly found that Winter Storm Uri prevented Pioneer’s performance, and that Pioneer exercised due diligence. The court also found no abuse of discretion in the admission of Pioneer’s expert testimony and exclusion of MIECO’s expert testimony. The judgment of the district court was affirmed. View "Mieco v. Pioneer Natural Resources" on Justia Law

A seventy-year-old man with dementia and Alzheimer’s disease was involved in a late-night domestic violence incident at his home in El Paso, Texas. Police were called after his wife reported that he had become violent and tried to strangle her. Officer Jaso responded and found the man outside, where he ignored commands, picked up and threw objects at Jaso—striking him with at least one object. After repeated noncompliance and object-throwing, Jaso deployed his taser once, causing the man to fall and lose consciousness. The man was hospitalized and subsequently died.The man’s daughter, on behalf of his estate, brought suit under 42 U.S.C. § 1983 against Officer Jaso for excessive force and against the City of El Paso for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978). The United States District Court for the Western District of Texas granted summary judgment to both defendants. The court found Jaso was entitled to qualified immunity, concluding that the plaintiff failed to show Jaso’s single use of the taser violated clearly established law. The court also determined there was no evidence of the City’s deliberate indifference to a known or obvious risk of constitutional violation.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed. The court held that, even assuming a Fourth Amendment violation, no precedent clearly established that Jaso’s conduct was unlawful under the specific circumstances—namely, facing an actively resisting, noncompliant suspect who was throwing objects. The court also found that the plaintiff failed to show a pattern of similar constitutional violations or deliberate indifference by the City, and that arguments or evidence not presented to the district court could not be considered on appeal. The court denied the request for additional discovery and affirmed dismissal of all federal claims. View "Navejas v. City of El Paso" on Justia Law

Two consumers challenged two rules issued by the U.S. Department of Energy (DOE) that imposed new water-use standards for residential dishwashers and clothes washers. Their argument was that the DOE exceeded its statutory authority under the Energy Policy and Conservation Act (EPCA), which, they claimed, only authorized DOE to regulate four specific appliances (showerheads, faucets, water closets, and urinals). The DOE had issued direct final rules (DFRs) in 2024 that further reduced water-use limits and changed measurement schemes for dishwashers and clothes washers. The plaintiffs sought declaratory and injunctive relief in federal district court, asking it to invalidate the DOE’s rules and restore the standards set by Congress.The United States District Court for the Northern District of Texas dismissed the case for lack of subject matter jurisdiction. The district court found that EPCA’s statutory-review mechanism, specifically 42 U.S.C. § 6306(b), vested exclusive jurisdiction for challenges to rules prescribed under § 6295 in the circuit courts, not the district courts. The court rejected plaintiffs’ arguments for concurrent jurisdiction and their reliance on the EPCA’s “savings clause” in § 6306(b)(4), holding that neither provided a jurisdictional basis for their claims. The district court also denied a motion to alter or amend the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the plaintiffs had standing, as their alleged reduction in market choices constituted an injury in fact traceable to the challenged DOE rules. The Fifth Circuit then affirmed the district court’s dismissal, holding that the circuit courts have exclusive jurisdiction over challenges to DOE rules under EPCA and that the district court was properly stripped of jurisdiction. The judgment of the district court was affirmed. View "Word v. Department of Energy" on Justia Law

A man convicted of murder in Texas and sentenced to death sought to halt his execution, scheduled for October 7, 2026. He argued that newly developed clinical standards for diagnosing intellectual disability, which became available after his first federal habeas petition, would now classify him as intellectually disabled and therefore constitutionally ineligible for execution. He maintained that these new clinical guidelines constituted either a new rule of constitutional law or a new factual predicate, justifying a second federal habeas petition under 28 U.S.C. § 2254. As an alternative, he requested a stay of execution pending a potential relevant decision by the United States Supreme Court.After his 2001 conviction, the Texas Court of Criminal Appeals rejected his Eighth Amendment claim that his mental illness barred execution. His first state and federal habeas petitions were denied, with the federal courts determining in 2017 that he was not intellectually disabled. He later abandoned his initial Atkins v. Virginia claim after the Supreme Court faulted Texas’s standards for such claims in Moore v. Texas. In 2019, the United States District Court for the Eastern District of Texas denied his remaining federal habeas claims, and the United States Court of Appeals for the Fifth Circuit denied a Certificate of Appealability in 2020.Reviewing the case, the United States Court of Appeals for the Fifth Circuit held that the petitioner’s second federal habeas application was barred by the one-year statute of limitations and that he was not entitled to equitable tolling. The court further found that his renewed claim of intellectual disability had already been presented in his prior habeas petition, barring reconsideration under § 2244(b)(1). The court also denied his request for a stay of execution, finding no likelihood of success on the merits and no justification for equitable relief. Both motions were denied. View "In re Howard" on Justia Law

A patient underwent surgery in Texas, during which a specific surgical stapler and staple product were used to reconnect sections of his colon. After initial success, he suffered severe complications days later, including sepsis, allegedly caused by a defect in the staple line. This resulted in months of treatment and ultimately his death. His widow and children sued several product manufacturers and sellers, asserting claims for breach of implied warranty of merchantability and other product liability theories.Initially, the plaintiffs brought suit in the United States District Court for the Western District of Texas against Johnson & Johnson, Ethicon, and Ethicon Endo-Surgery, Inc. (“Phillips I”). Discovery revealed confusion about the identity of the actual seller, prompting the plaintiffs to file an amended complaint against Ethicon Endo-Surgery, Inc. alone, asserting only breach of warranty claims. The magistrate judge recommended dismissing the claim for breach of implied warranty of merchantability without prejudice, primarily due to lack of presuit notice required under Texas law. The district court instead dismissed both claims with prejudice and denied leave to amend, finding that amendment would be futile and that the plaintiffs had not provided proper notice or shown how they could cure the defect.After dismissal in Phillips I, the plaintiffs filed a second suit in state court (“Phillips II”) against additional parties. This case was removed to federal court, where the defendants moved for dismissal based on res judicata and collateral estoppel. The district court adopted the magistrate judge’s recommendation and dismissed Phillips II with prejudice. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed both district court judgments, holding that plaintiffs failed to state a claim due to lack of presuit notice, the denial of leave to amend was not an abuse of discretion, and preclusion doctrines properly barred the second suit. View "Phillips v. Ethicon Endo-Surgery" on Justia Law

Two individuals received fines after failing to pay parking charges at garages operated by a company that uses automated technology, such as cameras and QR codes, to manage parking payments. When the plaintiffs did not pay the required parking fees, the company mailed them notices demanding the original fee plus a significantly larger fine. The plaintiffs alleged that the company’s business model intentionally made it difficult for drivers to pay, thereby increasing the likelihood of nonpayment and enabling the company to collect higher fines.The plaintiffs brought a putative class action in the United States District Court for the Northern District of Texas, asserting claims under the Fair Debt Collection Practices Act (FDCPA), as well as related Texas statutes. They argued that the company qualified as a “debt collector” under the FDCPA because it mailed notices demanding payment. The company moved to dismiss, and a magistrate judge recommended dismissal, finding that the company’s principal business was operating parking lots, not debt collection, and that it did not collect debts on behalf of others. The district court dismissed the FDCPA claim with prejudice, concluding the company was not a debt collector since it originated the debt and thus fell within a statutory exception. The court declined to exercise supplemental jurisdiction over the state law claims and denied leave to amend, finding any amendment would be futile.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court misapplied the statutory exception for debt originators. The Fifth Circuit clarified that to invoke this exception, a party must both collect debts on behalf of others and have originated the debt. However, the court affirmed the dismissal on alternative grounds, holding that the plaintiffs failed to state a plausible claim that the company was a debt collector under the FDCPA because they did not sufficiently allege either that debt collection was the company's principal purpose or that it regularly collected debts for others. The Fifth Circuit also affirmed the denial of leave to amend. View "Frankfort v. Metropolis Technologies" on Justia Law

David Koan pled guilty in federal court to two counts of producing child pornography, offenses that arose from the same conduct underlying his prior Texas state conviction for aggravated sexual assault of a child. For the state offenses, Koan had already been sentenced to 35 years in prison and had served nearly 40 months in custody by the time of his federal sentencing. The federal presentence report recognized that the state and federal offenses were related and recommended that Koan's federal sentence be adjusted under U.S.S.G. § 5G1.3(b) to account for the time already served on his undischarged state term.In the United States District Court for the Northern District of Texas, Koan was sentenced to 60 years in prison—30 years on each count, to run consecutively—but the court ordered the federal sentence to run concurrently with the remaining state sentence. When defense counsel requested that Koan be given credit for the time already served in state custody, the district court stated it lacked authority to do so and deferred the issue to the Bureau of Prisons. The district court did not address the relevant Guideline provision or make clear reference to the statutory sentencing factors.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that Koan had properly preserved his challenge concerning the application of U.S.S.G. § 5G1.3(b). The court held that the district court erred by failing to consider its authority under § 5G1.3(b) to adjust Koan’s sentence to account for time served on the related state conviction, mistakenly believing that only the Bureau of Prisons could award such credit. The Fifth Circuit vacated the sentence and remanded the case for resentencing so that the district court could properly consider and apply § 5G1.3(b). View "USA v. Koan" on Justia Law

A faith-based auto repair company, which exclusively franchises to professing Christians, denied a franchise application from an individual who is both ethnically and religiously Jewish. The applicant had advanced through several steps in the franchise process before being informed that his Jewish faith disqualified him. The company’s franchisees include people of various ethnic backgrounds, including some ethnic Jews who are Christians.The applicant sued the company in the United States District Court for the Southern District of Texas, alleging racial discrimination under 42 U.S.C. § 1981. He claimed the denial was based on his Jewish ethnicity or that no meaningful distinction exists between Jewish ethnicity and Jewish faith. The company argued its decision was based solely on religious criteria, not ethnicity, and moved to dismiss. The district court denied the motion, finding that the applicant had adequately alleged racial discrimination. Later, on summary judgment, the district court applied the McDonnell Douglas framework, found the applicant established a prima facie case, but concluded the company provided a legitimate, race-neutral reason—its Christian-only policy—and there was no evidence of pretext. Summary judgment was granted for the company.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the grant of summary judgment de novo. The court held that § 1981 prohibits racial but not religious discrimination in contracting, reaffirming Supreme Court and circuit precedent. It found no evidence that the company’s policy was a pretext for ethnic discrimination, distinguishing between Jewish ancestry (covered by § 1981) and Jewish faith (not covered). The Fifth Circuit affirmed the district court’s judgment, holding that § 1981 does not reach religious discrimination and that the applicant’s claim failed for lack of evidence of racial discrimination. View "Domanic v. Christian Brothers" on Justia Law