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

After the death of Juan Chavez, his family members brought a wrongful death action in Texas state court against several defendants, including United Parcel Service, Inc. (UPS) and a group of other companies alleged to be involved in the incident. After the initial suit was voluntarily dismissed, the plaintiffs filed a new action in state court, naming the same defendants as well as an additional Texas-based defendant, Fusion Recycling, LLC. UPS removed the case to federal court, asserting diversity jurisdiction, but plaintiffs argued that Fusion’s inclusion defeated diversity. UPS countered that Fusion was improperly joined and should not be considered for jurisdictional purposes.The United States District Court for the Northern District of Texas, acting sua sponte, remanded the case to state court. The court found that UPS’s notice of removal failed to establish the plaintiffs’ citizenship, as it relied only on allegations of residency and not citizenship. The district court did not give UPS an opportunity to cure this deficiency and did not make an affirmative finding that complete diversity was lacking.On appeal, the United States Court of Appeals for the Fifth Circuit considered whether it had jurisdiction to review the remand order. The Fifth Circuit determined that the district court’s remand was based on a procedural defect—specifically, insufficient pleading of citizenship—rather than a determination of subject matter jurisdiction. Because the remand was sua sponte and not based on a plaintiff’s motion, the appellate bar under 28 U.S.C. § 1447(d) did not apply. The Fifth Circuit held it had jurisdiction to review the remand order and found that UPS’s allegations of citizenship, made upon information and belief and supported by residency facts, were sufficient at this early stage. The court vacated the remand order and returned the case for further proceedings. View "De Chavez v. UPS" on Justia Law

A company based in Texas purchased a group of telecommunications patents and soon after sued another company for patent infringement in several European courts, including the European Union’s Unified Patent Court (UPC) and a German district court. The defendant in those foreign proceedings argued that its products did not infringe the patents and, in the alternative, that the patents must be licensed on fair, reasonable, and nondiscriminatory (FRAND) terms. To support its FRAND defense, the defendant sought access to an unredacted patent purchase agreement, which it believed contained information relevant to the appropriate licensing terms.After the UPC denied the defendant’s request for production of the unredacted agreement—finding the request unsubstantiated and the information likely irrelevant at that stage—the defendant applied to the United States District Court for the Northern District of Texas for discovery under 28 U.S.C. § 1782. A federal magistrate judge granted the discovery request, and the district court affirmed, applying a deferential standard of review and requiring the plaintiff to provide “authoritative proof” that the European courts would not be receptive to the discovery.On appeal, the United States Court of Appeals for the Fifth Circuit concluded that the district court erred in both its standard of review and its allocation of the burden of proof. The Fifth Circuit clarified that district courts must review magistrate judge recommendations on § 1782 applications de novo, as such applications are dispositive. The Court further held that respondents are not required to provide authoritative proof of foreign court non-receptivity and that the lower court misapplied the discretionary factors set out in Intel Corp. v. Advanced Micro Devices, Inc. The appellate court found that the balance of factors weighed against permitting discovery at this time and reversed the district court’s order granting discovery. View "Motorola v. Advanced Standard Communication" on Justia Law

The defendant was charged with possession of methamphetamine with intent to distribute under federal law. He ultimately pled guilty and, as part of his plea agreement, he waived his right to appeal his conviction and sentence, except for claims of ineffective assistance of counsel. During the plea process, the defendant confirmed in open court that he had read, discussed, and understood the terms of the plea agreement, including the appeal waiver. He was sentenced to 240 months in prison. The conduct underlying the sentencing enhancements involved the defendant fleeing law enforcement by driving through residential property, which led to the district court applying certain enhancements to his sentence.Following sentencing, the defendant appealed to the United States Court of Appeals for the Fifth Circuit, challenging the application of sentencing enhancements and arguing his appeal waiver was not knowing and voluntary. The government argued that the appeal should be dismissed based on the waiver. The Fifth Circuit initially dismissed the appeal, enforcing the waiver. The Supreme Court of the United States then decided Hunter v. United States, establishing that appeal waivers are unenforceable if enforcing them would result in a miscarriage of justice. The Supreme Court vacated the Fifth Circuit’s judgment and remanded the case for reconsideration under the Hunter standard.On remand, the United States Court of Appeals for the Fifth Circuit determined that the defendant’s waiver was knowing and voluntary. The court further found that, under the Hunter standard, the alleged sentencing errors were not the type of egregious errors that would constitute a miscarriage of justice. As a result, the Fifth Circuit enforced the appeal waiver and dismissed the appeal. The court’s holding was that no miscarriage of justice occurred, and the appeal waiver remained enforceable. View "USA v. Harris" on Justia Law

The plaintiff worked as a cleanup worker in Pascagoula, Mississippi, following the 2010 Deepwater Horizon oil spill, allegedly exposed to crude oil and chemical dispersants through inhalation and direct contact. He claimed this exposure caused a chronic worsening of his preexisting asthma. The plaintiff sued BP Exploration & Production, Inc. and BP America Production Company under the Back-End Litigation Option (BELO) of the Medical Settlement Agreement related to the Deepwater Horizon class-action litigation. The parties stipulated to venue in the United States District Court for the Southern District of Mississippi.The litigation required the plaintiff to prove that his injuries were legally caused by exposure to oil spill-related substances. He proffered two experts, Dr. Michael Freeman and Dr. Shawn French, to establish causation. BP moved to exclude their testimony and for summary judgment. The district court denied the plaintiff’s request for an evidentiary hearing, excluded the expert testimony, and granted summary judgment in favor of BP, finding that the expert evidence was insufficient to raise a genuine issue of material fact as to causation. The plaintiff timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that toxic tort causation standards, requiring expert testimony to establish both general and specific causation, apply under maritime law for BELO claims involving non-readily observable injuries with multiple possible etiologies. The Fifth Circuit found the district court did not abuse its discretion in excluding the plaintiff’s experts, both for lack of reliability and relevance under Rule 702 and Daubert, and for deficiencies in qualifications and methodology. The district court’s grant of summary judgment was affirmed. View "Dufour v. BP Exploration & Production" on Justia Law

Eva Stramaski, an academic advisor at Texas A&M University, was concerned her paycheck might arrive late after returning from medical leave. Despite being paid on time, her supervisor, Mark Lawley, accused her of being “aggressive” about the issue, sent her home, and issued a “coaching letter” citing performance problems. Stramaski disputed these allegations, and Lawley fired her a few days later. She then brought suit against Lawley in his personal capacity under the Fair Labor Standards Act (FLSA), claiming retaliation for asserting her right to timely pay.The United States District Court for the Southern District of Texas first heard the case. Lawley moved to dismiss the suit, arguing sovereign immunity and qualified immunity. A magistrate judge recommended dismissing claims for injunctive and declaratory relief but rejected both immunity defenses, and the district court adopted the recommendations over Lawley’s objections. Lawley appealed. In its first review (Stramaski I), the United States Court of Appeals for the Fifth Circuit held that sovereign immunity did not bar the case against Lawley personally but left open the issue of qualified immunity, remanding for further analysis. On remand, the district court again denied Lawley’s qualified immunity defense, and Lawley appealed a second time.The United States Court of Appeals for the Fifth Circuit, in this second appeal, addressed whether a public official may invoke qualified immunity in an FLSA retaliation suit. The court held that qualified immunity does not apply to such claims. It reasoned that, at the time Congress authorized private FLSA retaliation suits, the common law did not shield officials from malicious retaliation, and the purposes underlying qualified immunity are incompatible with the FLSA’s anti-retaliation protections. The court affirmed the district court’s denial of Lawley’s motion to dismiss. View "Stramaski v. Lawley" on Justia Law

James Bien worked as a conductor for Union Pacific Railroad Company. In 2013, he failed two vision tests required for his job and was subsequently removed from his conductor position, receiving a work restriction that prevented him from performing duties requiring color signal recognition. After several months, he was employed by Union Pacific in a different, lower-paying role. In 2015, following a notification from the company, Bien took another vision test, which he passed. He then requested a follow-up test to potentially remove his work restriction and be reinstated as a conductor. Union Pacific denied this request, determining that his prior test failures were dispositive and that the new test had been administered in error. Bien filed a discrimination charge with the EEOC in April 2020 and later brought suit under the Americans with Disabilities Act (ADA) in January 2025.Prior to Bien's lawsuit, a class action had been filed in the District of Nebraska, Harris v. Union Pacific Railroad Company, challenging similar employment actions by Union Pacific. The initial class definition was broad, but the court later certified a narrower class. The United States District Court for the Eastern District of Texas concluded that Bien fell within the original class definition but not the certified, narrower one, reasoning that his 2015 testing and related correspondence did not constitute a “fitness-for-duty examination” under the certified class. As a result, the district court held that the statute of limitations barred Bien’s claim and dismissed his case.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The Fifth Circuit held that, under American Pipe tolling, a plaintiff must be unambiguously excluded from a class definition to terminate tolling of the statute of limitations. Because Bien was not unambiguously excluded from the certified class, he was entitled to tolling, and his suit was not time-barred. The case was remanded for further proceedings. View "Bien v. Union Pacific" on Justia Law

A coach and teacher employed by a Texas school district, along with his wife and their son, brought suit after two separate incidents involving the school and its employees. The first incident occurred when the coach’s son was accused by a fellow student of inappropriate conduct, resulting in the seizure of a phone, a public escort through the school by security personnel, and alleged detention and interrogation of the son. The father was sanctioned and ordered not to return to work, and the family claims these actions harmed their reputations and career prospects. The second incident took place the following year when the coach attended a school board meeting to celebrate his team’s achievements. During the event, he refused to shake hands with certain board members and employees, citing both personal grievances and a desire to avoid the appearance of political endorsement. He was subsequently warned and transferred to another school, which he alleges was retaliation.The United States District Court for the Southern District of Texas dismissed several of the plaintiffs’ claims. The court found no Fifth Amendment violation because the plaintiffs did not allege that any compelled statements were used against them in a criminal case. Regarding the First Amendment claim, the court concluded that the coach’s conduct at the board meeting was undertaken in his official capacity, not as a private citizen, and primarily concerned personal matters rather than public concern. The court also dismissed the related Texas constitutional claim for similar reasons. Other claims were voluntarily dismissed by the plaintiffs, and a final judgment was issued.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissals de novo and affirmed. The appellate court held that the plaintiffs failed to allege a plausible Fifth Amendment violation under Chavez v. Martinez because no compelled statement was used in a criminal case. It further held that the coach’s actions at the board meeting were not protected speech under the First Amendment, as they arose from his official duties rather than as a private citizen. The dismissal of related claims under state law was also affirmed. View "Lucio v. Brownsville Independent School District" on Justia Law

A group of Facebook users who interacted with an optical retailer’s website alleged that the company installed a Meta Pixel tracking tool on its site, which collected and transmitted users’ sensitive health-related information—such as browsing for prescription eyewear, entering prescription details, and scheduling eye exams—to Meta Platforms, Inc. without their consent. The users claimed this information qualified as individually identifiable health information under federal law and should not have been shared without authorization. The plaintiffs divided themselves into two groups: those who browsed or scheduled appointments (“Search Plaintiffs”) and those who entered prescription information to purchase eyewear (“Prescription Plaintiffs”).The United States District Court for the Northern District of Texas initially found that the plaintiffs had standing but dismissed their first complaint for failure to state a claim, allowing them to amend. After the plaintiffs filed their amended complaint, the district court again dismissed the case with prejudice. It held that the Search Plaintiffs had not adequately alleged they shared any protected health information with the defendant, and that the Prescription Plaintiffs had failed to show any such information was actually disclosed to Meta through the Pixel.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The Fifth Circuit concluded that the unauthorized disclosure of the plaintiffs’ health information to Meta constituted a concrete and particularized injury, affirming that the plaintiffs had standing. The court held that both groups of plaintiffs adequately alleged that their individually identifiable health information was transmitted to Meta without their consent. The Fifth Circuit therefore reversed the district court’s dismissal and remanded the case for further proceedings. View "Rand v. Eyemart Express" on Justia Law

Three individuals, all foreign nationals who had resided in the United States for many years without lawful admission, were detained by immigration authorities under 8 U.S.C. § 1225(b)(2)(A) following traffic stops. Each sought habeas corpus relief, arguing that their continued detention without a bond hearing to assess their dangerousness or flight risk violated their Fifth Amendment due process rights.The United States District Court for the Western District of Texas granted habeas relief in each case, ordering the release of the individuals and enjoining federal authorities from further detaining them absent individualized bond hearings. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit affirmed the district courts’ rulings, holding that the Fifth Amendment required a bond hearing within 90 days of detention. The panel also consolidated the cases due to their similar legal questions regarding detention under § 1225(b)(2)(A).The United States Court of Appeals for the Fifth Circuit, sitting en banc, subsequently reconsidered the panel’s decision. The en banc court held that unadmitted aliens detained under § 1225(b)(2)(A) are not constitutionally entitled to individualized hearings on dangerousness or flight risk before detention, and that the duration of their detention did not present constitutional concerns warranting habeas relief. The court reasoned that such procedural protections are not required by the statute, nor by the Fifth Amendment, given Congress’s plenary power over immigration and the specific statutory framework for applicants for admission. Accordingly, the Fifth Circuit reversed the district courts’ judgments and vacated their orders granting habeas relief to the petitioners. View "Alvarado v. Vergara" on Justia Law

In this case, a group of teachers, professors, students, parents, and advocacy organizations challenged the constitutionality of a recently enacted Mississippi law, House Bill 1193, which restricts the use of state education funds for diversity, equity, and inclusion (DEI) initiatives in public schools and colleges. The law prohibits the mandatory implementation of DEI programs, penalizing students for disagreeing with DEI concepts, promoting DEI through official course materials, and engaging in DEI activities in official capacities, while carving out exceptions for scholarly research, creative works, and student group activities.After the plaintiffs filed a pre-enforcement facial challenge on First Amendment and Fourteenth Amendment grounds, the United States District Court for the Southern District of Mississippi issued a temporary restraining order (TRO) and later a preliminary injunction blocking the law’s enforcement. The district court’s proceedings, however, were marred by multiple errors: the TRO included fabricated facts, non-existent parties, and a citation to a fictitious case, some of which stemmed from the judge’s or his clerk’s reliance on artificial intelligence in drafting. When these issues came to light, the judge revised the TRO without adequate explanation and incorporated the flawed order by reference into the preliminary injunction. The district court’s legal analysis was also found deficient, failing to properly apply binding Supreme Court precedent and misinterpreting the requirements for facial constitutional challenges.The United States Court of Appeals for the Fifth Circuit reviewed the case and found grave procedural and substantive errors in the district court’s handling, including the use of fabricated evidence, failure to follow controlling legal standards, and an overbroad injunction. The Fifth Circuit vacated the preliminary injunction, holding that the errors justified reassignment of the case to a different district judge on remand. The court provided detailed instructions for the new judge, emphasizing the need to follow the Supreme Court’s framework for facial First Amendment challenges and to properly analyze the law’s scope and constitutionality. The disposition was to vacate the injunction and remand the case for further proceedings before a new judge. View "Jackson Federation of Teachers v. Fitch" on Justia Law