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

Fieldwood Energy operated an offshore platform near Louisiana and contracted with United Fire and Safety to provide fire watch services for repairs. Fieldwood also separately chartered a liftboat from Aries Marine to support the work, which included housing and crane services for the contractors. During the project, the liftboat listed and capsized, leading to personal injuries for a United Fire employee. Aries Marine, facing liability claims, sought indemnification from United Fire based on a cross-indemnification clause in the 2013 Master Services Contract (MSC) between Fieldwood and United Fire.The United States District Court for the Eastern District of Louisiana considered cross-motions for summary judgment on whether the MSC was a maritime contract. The district court found that the contract was not maritime in nature, applying Louisiana law via the Outer Continental Shelf Lands Act (OCSLA), which incorporates the law of the adjacent state unless federal maritime law applies. Louisiana’s Oilfield Anti-Indemnity Act invalidated the indemnity provisions. Aries’s motions for reconsideration were denied, leading to this appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court agreed that the MSC did not require or contemplate that a vessel would play a substantial role in the contracted fire watch services. It found that only Fieldwood, not United Fire, expected the liftboat’s substantial involvement, and that such a shared expectation was necessary under circuit precedent to create a maritime contract. Because the parties did not share this expectation, the contract was not maritime, and Louisiana law voided the indemnity provisions. The Fifth Circuit affirmed the district court’s judgment. View "Aries Marine v. United Fire & Safety" on Justia Law

Several pharmaceutical manufacturers and a trade association challenged a Louisiana statute, Act 358, which restricts drug manufacturers from interfering with the delivery of federally discounted drugs through contract pharmacies. The statute was passed in response to manufacturers’ efforts to limit the distribution of discounted drugs under the federal 340B Program, particularly through arrangements with contract pharmacies serving vulnerable populations. The plaintiffs argued that the Louisiana law was preempted by federal law and violated several constitutional provisions, including the Takings Clause, the Contracts Clause, and the Due Process Clause’s prohibition on vagueness.The United States District Court for the Western District of Louisiana considered three related cases together. It denied the manufacturers’ motions for summary judgment and instead granted summary judgment for the State of Louisiana and the Louisiana Primary Care Association (LPCA) on all claims. The district court also allowed LPCA to intervene in each case, over the objection of one plaintiff.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that Act 358 is not preempted by federal law. It found that the federal 340B statute does not occupy the field of pharmacy regulation and does not conflict with or frustrate federal objectives, as it is silent on the use of contract pharmacies and leaves room for state regulation. The court also concluded that Act 358 does not effect a physical or regulatory taking, does not substantially impair contract rights under the Contracts Clause, and is not unconstitutionally vague. However, the Fifth Circuit reversed the district court’s order permitting LPCA to intervene in AbbVie’s case, finding that LPCA’s interests were adequately represented by the State and it did not show it would present a distinct defense. The court affirmed summary judgment for Louisiana on all claims. View "AstraZeneca v. Murrill" on Justia Law

The plaintiff worked as an Agency Manager for a group of insurance companies collectively known as Texas Farm Bureau. In this role, he supervised a team of insurance agents and was classified as an independent contractor. He determined his own work schedule, was not required to report his hours, and was paid through commissions rather than a salary or hourly wage. From 2016 to 2018, his earnings ranged from $552,000 to $627,000 per year. The plaintiff filed suit, claiming he was misclassified and seeking unpaid overtime under the Fair Labor Standards Act, arguing he should have been treated as an employee.The United States District Court for the Western District of Texas ruled at summary judgment that the plaintiff should have been classified as an employee and was owed at least 816 hours of overtime. The only issue left for trial was whether the employer knew or should have known about the plaintiff’s overtime work. A jury found that the employer neither had actual nor constructive knowledge of any overtime. The plaintiff’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of these motions. The appellate court held that an employee seeking overtime pay must prove the employer had actual or constructive knowledge of the overtime work. The court found that allowing an employee to set his own hours does not, by itself, establish employer knowledge of overtime. The lack of a timekeeping system did not constitute constructive knowledge, nor did it shift the burden of proof to the employer. The appellate court also held that the district court’s jury instruction, which required the employee to notify the employer of overtime, was proper. The Fifth Circuit affirmed the district court’s rulings. View "Merritt v. Texas Farm Bureau" on Justia Law

A Texas nonprofit health center, CentroMed, experienced a data breach in 2024 that exposed the personal information of its patients. Arturo Gonzalez, representing himself and others affected, filed a class action in Bexar County, Texas, alleging that CentroMed failed to adequately protect their private information. CentroMed, which receives federal funding and has occasionally been deemed a Public Health Service (PHS) employee under federal law, sought to remove the case to federal court, claiming removal was proper under 42 U.S.C. § 233 and 28 U.S.C. § 1442.After CentroMed was served, it notified the Department of Health and Human Services (HHS) and the United States Attorney, seeking confirmation that the data breach claims fell within the scope of PHS employee immunity. The United States Attorney appeared in state court within the required 15 days, ultimately informing the court that CentroMed was not deemed a PHS employee for the acts at issue because the claims did not arise from medical or related functions. Despite this, CentroMed removed the case to the United States District Court for the Western District of Texas 37 days after service. The district court granted Gonzalez’s motion to remand, concluding that removal was improper under both statutes: the Attorney General had timely appeared, precluding removal under § 233, and removal under § 1442 was untimely.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s remand. The Fifth Circuit held that CentroMed could not remove under § 233 because the Attorney General had timely appeared and made a case-specific negative determination. The court further held that removal under § 1442 was untimely, as CentroMed did not remove within 30 days of receiving the initial pleading. Thus, the remand to state court was affirmed. View "Gonzalez v. El Centro Del Barrio" on Justia Law

Two Mexican nationals entered the United States illegally, one in 2009 and the other in 2001. In 2025, both were apprehended by Department of Homeland Security (DHS) officials, who determined that they were inadmissible because they were present in the United States without having been lawfully admitted or paroled. Consequently, DHS initiated removal proceedings against both individuals and detained them under 8 U.S.C. § 1225(b)(2)(A) without bond pending the outcome of those proceedings.Each petitioner requested a bond hearing before an immigration judge, but both requests were denied on the grounds that § 1225(b)(2)(A) mandated detention without bond for “applicants for admission” who are not “clearly and beyond a doubt entitled to be admitted.” Subsequently, both individuals filed habeas corpus petitions in the United States District Court for the Southern District of Texas, arguing that they were entitled to bond hearings under 8 U.S.C. § 1226(a). The district courts agreed, concluding that because the petitioners were not actively “seeking admission” at the time of apprehension, their detention was governed by § 1226(a), which allows for discretionary bond. Both petitioners received bond hearings and were released.The United States Court of Appeals for the Fifth Circuit reviewed the consolidated government appeals. The Fifth Circuit reversed the district courts’ orders. The court held that individuals present in the United States without having been admitted—regardless of how long they have resided here—are deemed “applicants for admission” under § 1225(a)(1) and are therefore subject to mandatory detention under § 1225(b)(2)(A) without eligibility for bond during removal proceedings. The court found that the statutory text, structure, and context supported the government’s interpretation, and the prior practice of allowing bond did not override the statute’s plain meaning. The cases were remanded for further proceedings consistent with this holding. View "Buenrostro-Mendez v. Bondi" on Justia Law

Marquis Kennedy sought employment as a police officer with the City of Arlington, Texas, and enrolled in the Arlington Police Academy after passing a physical exam. During a mandatory training exercise known as Gracie Survival Tactics, which involved intense self-defense scenarios, Marquis reportedly complained of fatigue, thirst, and lightheadedness, but was not permitted breaks or water. He continued participating, allegedly due to fear of failing and repeating the training. During the final scenario, Marquis signaled distress, but the instructors continued the exercise until he could not proceed. After the simulation ended, Marquis requested an ambulance, was assisted to a break room, and subsequently suffered cardiac arrest. Emergency services were called, and Marquis was taken to a hospital, where he died two days later. The autopsy listed cardiac arrest as the cause of death, likely due to atherosclerotic cardiovascular disease.Kennedy, Marquis’s widow, brought suit in the United States District Court for the Northern District of Texas against the City and several officers, asserting Fourth and Fourteenth Amendment violations under 42 U.S.C. § 1983, including claims for excessive force, deliberate indifference to medical needs, bystander liability, and municipal liability for failure to train officers. The City moved to dismiss and submitted video evidence of the training, which Kennedy referenced in her claims. The magistrate judge recommended dismissal of all claims, finding no plausible constitutional violation, no constitutional seizure, and no duty of medical care in an employment setting. The district court adopted these findings and dismissed the case.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Kennedy failed to plausibly allege a Fourth Amendment seizure or substantive due process violation, and that no constitutional duty of medical care existed in this employment context. The court also found no basis for bystander or municipal liability. View "Kennedy v. City of Arlington, Texas" on Justia Law

Harvard Maintenance, a janitorial contractor in New York City, employed Carina Cruz as a cleaner. Cruz raised several complaints alleging violations of the collective bargaining agreement, including assignment of certain cleaning tasks and concerns about working conditions. In response to her complaints, Cruz faced threats from supervisors, was suspended following workplace disputes, and ultimately terminated in June 2020. Cruz filed a complaint with the National Labor Relations Board (NLRB), claiming her suspension and termination were unlawful reprisals for protected union activity.An administrative law judge (ALJ) for the NLRB found that Harvard Maintenance unlawfully threatened, suspended, and fired Cruz in violation of the National Labor Relations Act (NLRA) and ordered remedies including backpay, reimbursement for job search expenses, and compensation for “direct or foreseeable pecuniary harms.” The NLRB adopted the ALJ’s findings and order. Harvard Maintenance petitioned for review with the United States Court of Appeals for the Fifth Circuit, challenging the findings of coercive statements, unlawful discharge, and the scope of the awarded remedies.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the NLRB’s findings regarding coercive statements and unlawful discharge were supported by substantial evidence and affirmed those parts of the Board’s order. However, the Fifth Circuit concluded that the award of consequential damages for “direct or foreseeable pecuniary harms” exceeded the NLRB’s statutory authority under the NLRA, which permits only equitable remedies. Therefore, the court denied Harvard Maintenance’s petition for review as to the findings of unlawful conduct, but granted relief and vacated the portion of the order awarding consequential damages. The Board’s application for enforcement was granted except as to the consequential damages remedy. View "Harvard Maintenance v. National Labor Relations Board" on Justia Law

An international commodity trading company supplied marine fuel oil to a cargo vessel that was time chartered to a German company. Because the charterer had poor credit, a UAE-based sister company guaranteed its obligations under the charter. In October 2022, an employee of the guarantor sought fuel through a broker, which then contacted the trading company to arrange delivery. The broker communicated the quote and order details, and the fuel was delivered to the vessel in Spain. The trading company issued an invoice to the guarantor, but no payment was made by any party involved. The contract for the sale included a choice-of-law provision referencing United States law and incorporated general terms and conditions by reference.The United States District Court for the Eastern District of Louisiana reviewed the case after the vessel was arrested in New Orleans and the owner posted bond. The parties filed cross-motions for summary judgment, both of which were denied due to factual disputes. Following a bench trial, the district court found that the choice-of-law provision was effectively incorporated, and that the trading company was entitled to a maritime lien under American law. The court determined that the guarantor had apparent authority to bind the charterer in procuring the fuel, which in turn could bind the vessel. The district court awarded the trading company the amount invoiced, prejudgment interest, and custodia legis expenses.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that United States law governed the dispute due to valid incorporation of the choice-of-law provision and that the trading company was entitled to a maritime lien under the Commercial Instruments and Maritime Liens Act. The court found that the guarantor had apparent authority to act for the charterer and that the price charged for the fuel was reasonable under industry standards. View "Three Fifty Markets v. Argos M M/V" on Justia Law

A state trooper observed David Davalos commit a traffic violation by failing to signal a lane change. The trooper initiated a stop as Davalos pulled into the driveway of the home he shared with his parents. The driveway was open, with no fence or gate, and was adjacent to a public sidewalk and street. After blocking Davalos’s car, the officer instructed Davalos to exit the vehicle, which he did, leaving the driver’s side door open. The officer, concerned for his safety and unable to see into the car due to heavily tinted windows, approached and smelled marijuana, saw ashes, and noticed the driver’s side door appeared tampered with. After Davalos admitted to recently smoking marijuana and possessing a small amount, the officer searched the car and discovered marijuana and a firearm.Davalos was charged with possession of a firearm by a convicted felon in the United States District Court for the Western District of Texas. Prior to trial, he moved to suppress the evidence from the warrantless search, arguing the search violated the Fourth Amendment because the car was within the home’s curtilage and no exigent circumstances existed. A magistrate judge found the driveway was not part of the curtilage and recommended denying the motion, concluding the officer had probable cause and exigent circumstances justified the search. The district court adopted this recommendation, and Davalos entered a conditional guilty plea preserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Fifth Circuit held that the officer’s actions were permissible under the Fourth Amendment. The court found that probable cause and exigent circumstances justified the warrantless search of the car, regardless of curtilage questions, and affirmed the denial of Davalos’s motion to suppress. The judgment of the district court was affirmed. View "United States v. Davalos" on Justia Law

Eugene Lockhart pleaded guilty to conspiracy to commit wire fraud and bank fraud under federal law and was sentenced to 54 months in prison, followed by supervised release and joint restitution of over $2.4 million. Although Lockhart attempted to appeal pro se, his appeal was dismissed for lack of prosecution. Later, several of his codefendants successfully reduced their restitution obligations on appeal. Lockhart completed his supervised release in May 2017. In September 2023, he filed a petition for writ of coram nobis, seeking to vacate his conviction and restitution order, alleging ineffective assistance of counsel due to his attorney’s failure to appeal and preserve issues regarding restitution.The United States District Court for the Northern District of Texas denied Lockhart’s petition. The court found the petition untimely and determined it lacked jurisdiction to vacate the restitution order, reasoning that such a challenge could only be raised on direct appeal. The district court also concluded that Lockhart’s ineffective assistance claim did not warrant coram nobis relief because he had not diligently sought prompt relief after his supervised release ended.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision, applying de novo review to jurisdictional issues and abuse of discretion to the denial of the writ. The Fifth Circuit clarified that a coram nobis petition may seek to vacate a conviction, and if granted, any related restitution order would be vacated as well. However, the court held that Lockhart failed to exercise reasonable diligence in seeking relief, as he waited over six years after his supervised release ended to file the petition without justification. Accordingly, the Fifth Circuit affirmed the district court’s denial of Lockhart’s writ of coram nobis. View "United States v. Lockhart" on Justia Law