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

Christopher Dallas Nelson pleaded guilty to one count of possession of child pornography. The Presentence Investigation Report (PSR) revealed that Nelson possessed 3,699 images, including 196 images of his seven-year-old daughter and 25 images of his five-year-old daughter. Nelson admitted to downloading child pornography and taking images of his older daughter but denied producing images of his younger daughter. He also attempted to obstruct justice by hiding a laptop and cellphone containing evidence. Nelson's total offense level under the U.S. Sentencing Guidelines was 43, and he filed objections to the PSR.The United States District Court for the Western District of Texas sentenced Nelson to 240 months in prison, a $250,000 fine, additional restitution and special assessments totaling $10,100, and supervised release for life. The court imposed mandatory and standard conditions of supervised release and added discretionary special conditions barring Nelson’s access to the Internet. Nelson objected to these special conditions, and the court’s written judgment contained less severe versions of the Internet-related conditions. Nelson timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of a sentencing reduction for acceptance of responsibility, finding no abuse of discretion. The court also found that the written judgment conflicted with the oral pronouncement regarding Internet restrictions, holding that the oral pronouncement controls. Finally, the court held that the district court abused its discretion by imposing a lifetime Internet ban without exceptions, as it was not narrowly tailored. The court affirmed Nelson’s sentence except for the special conditions of supervised release, vacated the Internet-related conditions, and remanded for further proceedings. View "U.S. v. Nelson" on Justia Law

Michael Ray Senn was convicted in a Texas state court of sexual assault and prohibited sexual conduct with his intellectually disabled daughter, Brenda, who has an IQ of 64 and the competence of a preteen. In 2011, Senn raped Brenda, resulting in her pregnancy and the birth of a child in January 2012. DNA testing confirmed Senn as the biological father. A Texas jury found Senn guilty and applied a sentencing enhancement under Texas Penal Code Section 22.011(f), which increased the maximum sentence to life imprisonment because Senn was already married at the time of the assault.Senn's conviction and sentence were affirmed on direct appeal by the Texas Court of Appeals. The Texas Court of Criminal Appeals vacated the initial appellate decision and remanded the case for reconsideration in light of its decision in Arteaga v. State. On remand, the appellate court initially found insufficient evidence for the enhancement but was later overruled by the Texas Court of Criminal Appeals in Lopez v. State, which clarified that the enhancement applied if the defendant was married to someone other than the victim at the time of the assault. Senn's subsequent appeals, including an equal protection challenge, were rejected by the Texas courts.Senn then filed a federal habeas corpus petition, arguing that the application of the sentencing enhancement violated the Equal Protection Clause. The United States District Court for the Northern District of Texas denied his petition, holding that the state court's decision was not contrary to or an unreasonable application of clearly established federal law under the Anti-Terrorism and Effective Death Penalty Act (AEDPA).The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court held that Senn failed to demonstrate that the state court's application of the law was unreasonable or contrary to clearly established federal law, specifically noting that the enhancement had a rational basis in protecting children and vulnerable individuals from sexual exploitation. View "Senn v. Lumpkin" on Justia Law

In September 8, 2018, Michael Holmes attended a public fair in Belle Chasse, Louisiana, to test a new camera lens. While taking photos, Holmes was approached by Deputy Sheriff Corbett Reddoch, who asked for his identification. Holmes questioned the request, leading to a physical altercation where Reddoch arrested Holmes, claiming he was taking pictures of children. Holmes was charged only with resisting arrest.Holmes filed a lawsuit in the United States District Court for the Eastern District of Louisiana, asserting claims under 42 U.S.C. § 1983 and Louisiana state law. The jury found in favor of Holmes on his Fourth Amendment unlawful arrest claim but granted qualified immunity to Reddoch for the investigatory stop. The jury also found for Holmes on state-law claims of battery, false imprisonment, and malicious prosecution. Reddoch's post-verdict motions for judgment as a matter of law and a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of Reddoch's motions, holding that there was sufficient evidence for the jury to conclude that Reddoch did not have probable cause to arrest Holmes. The court also found that Reddoch forfeited his qualified immunity defense for the false arrest claim by not raising it in his Rule 50 motion. Additionally, the court held that the jury's verdicts on the investigatory stop and arrest were not inconsistent, as they involved different legal standards. The court also upheld the jury's award of punitive damages, finding that Reddoch's actions demonstrated reckless or callous indifference to Holmes's constitutional rights. The judgment of the district court was affirmed. View "Holmes v. Reddoch" on Justia Law

Caitlin Julia Weathers, a white woman, was hired by Houston Methodist Hospital as a Patient Transporter in May 2019 and later became a Patient Care Assistant in June 2021. She reported racial harassment and discrimination by her co-workers to her supervisor, Sunila Ali, and Human Resources (HR). HR investigated but found no evidence supporting her claims and instead received negative feedback about her performance. Weathers was placed on a performance improvement plan (PIP) and was eventually terminated on October 4, 2021, for allegedly failing to meet the PIP's expectations. Weathers claimed her termination was retaliatory.Weathers filed an online inquiry with the EEOC on February 11, 2022, but faced difficulties scheduling an interview due to the EEOC's unavailability. After several delays and cancellations, she finally had an interview on August 1, 2022, and filed her charge of discrimination on August 3, 2022, 303 days after her termination. The EEOC issued a Right to Sue letter on August 11, 2022. Weathers then sued Methodist and Ali for discrimination and retaliation under Title VII. The district court dismissed her claims against Ali, citing that employees are not personally liable under Title VII, and dismissed her claims against Methodist as time-barred for not filing within the 300-day deadline.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the dismissal of claims against Ali but found that the district court erred in not applying equitable tolling to Weathers's claims against Methodist. The court noted that the delays were partly due to the EEOC's actions and that Weathers had diligently pursued her claim. The court vacated the district court's judgment for Methodist and remanded the case for further proceedings, allowing Weathers's claims to proceed. View "Weathers v. Houston Methodist Hospital" on Justia Law

Beneficiaries of a family trust sued the co-trustees, alleging mismanagement and the creation of a secret trust to withhold funds. They sought a declaratory judgment, accountings, and damages. The district court excluded all evidence of damages due to the beneficiaries' failure to provide a damages calculation as required by Federal Rule of Civil Procedure 26. Consequently, the district court granted summary judgment in favor of the co-trustees, as the beneficiaries could not prove damages and were not entitled to a declaratory judgment or accountings.The United States District Court for the Western District of Louisiana initially handled the case. The court granted the co-trustees' motion in limine to exclude damages evidence and subsequently granted summary judgment on all claims. The court found that the beneficiaries failed to provide a timely damages calculation and that their claims were time-barred under Louisiana law. The beneficiaries appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision, holding that the district court did not abuse its discretion in excluding the damages evidence. The appellate court applied the "CQ factors" to determine that the exclusion was justified due to the importance of the evidence, the prejudice to the co-trustees, the availability of a continuance, and the beneficiaries' lack of a valid explanation for their delay. Consequently, the court affirmed the summary judgment on all claims, as the beneficiaries could not prove an essential element of their case without the excluded damages evidence. The court also affirmed the dismissal of the beneficiaries' request for a declaratory judgment, as it was remedial in nature and dependent on the underlying claims for recovery. View "King v. King" on Justia Law

Employees of Smith International, Inc. filed a claim for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The employees, known as reamers, supervised the use of Smith’s underreaming tool on offshore drilling rigs. They were paid an annual salary plus daily-rate job bonuses, with their total annual compensation exceeding $100,000. The employees argued that they were misclassified as exempt from overtime requirements and sought to recover unpaid overtime wages, liquidated damages, and attorney fees.The United States District Court for the Western District of Louisiana conditionally certified the action as a collective action. Later, the claims of some plaintiffs were severed into separate individual actions, while others continued as a collective action. The district court consolidated the five proceedings for all purposes except for trial. After discovery, both parties filed cross motions for summary judgment. The district court granted Smith’s motion for summary judgment, finding that the employees were exempt from the FLSA’s overtime pay guarantee as bona fide executives. The employees appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that each employee met the criteria for the bona fide executive exemption under the FLSA. Specifically, the employees satisfied the salary basis test, the salary level test, and the job duties test. The court found that the employees were paid a guaranteed annual salary, which was not subject to reduction based on the quality or quantity of work performed, and that the additional daily-rate compensation did not defeat their qualification for the exemption. The court affirmed the district court’s grant of summary judgment in favor of Smith International, Inc. View "Venable v. Smith International" on Justia Law

In the early morning of December 21, 2019, Corey Spiller went to assist his girlfriend, Dashanelle Moore, after her minor car accident on a Houston expressway. While conversing with officers at the scene, Sergeant Jared Lindsay arrived and directed Moore to a nearby truck stop for further procedures, instructing Spiller to follow in his car. When Spiller questioned the officers about Moore, Lindsay became enraged, seized Spiller by the neck, and slammed him onto a parked car, leading to a scuffle where Spiller was tased and arrested. The charges against Spiller were later dropped.Spiller filed a lawsuit under 42 U.S.C. § 1983 against Lindsay, Harris County, Harris County Constable Precinct 7, and Chief Constable May Walker, alleging excessive force, false arrest, bystander liability, retaliation, and ADA violations. The United States District Court for the Southern District of Texas dismissed claims against Harris County, Precinct 7, and Walker for failure to state a claim and granted summary judgment for Lindsay on the basis of qualified immunity. Spiller appealed, challenging the summary judgment on his Fourth Amendment excessive force, false arrest, First Amendment retaliation, and bystander liability claims against Lindsay, and the dismissal of his Monell claim against Harris County.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court’s summary judgment for Lindsay on the excessive force claim, finding genuine disputes of material fact regarding whether Lindsay's use of force was excessive and whether Spiller's actions justified such force. The court affirmed the district court’s rulings on the false arrest and First Amendment retaliation claims, concluding that Lindsay had probable cause for Spiller’s arrest. The court also upheld the dismissal of Spiller’s Monell claim against Harris County for failing to allege specific facts linking his injury to a county policy or custom. The case was remanded for further proceedings consistent with the opinion. View "Spiller v. Harris County" on Justia Law

Two whistleblowers, John M. Barr and John McPherson, challenged the Securities and Exchange Commission’s (SEC) calculation of their award amounts under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The case involves Life Partners Holdings, Inc., which was found guilty of extensive securities fraud from 1999 to 2013. In 2012, the SEC filed a civil action against Life Partners, resulting in a $38.7 million judgment. Life Partners subsequently filed for Chapter 11 bankruptcy to avoid the appointment of a receiver. The bankruptcy court appointed a Chapter 11 trustee, and a reorganization plan was confirmed in 2016.The SEC posted a Notice of Covered Action in 2015, inviting whistleblowers to apply for awards. Barr and McPherson submitted applications. The SEC’s Claims Review Staff initially recommended denying Barr an award and granting McPherson 23% of the collected sanctions. After objections, the SEC revised its decision, granting Barr 5% and McPherson 20% of the collected amounts. The SEC argued that the bankruptcy proceedings did not qualify as a “covered judicial or administrative action” or a “related action” under the Dodd-Frank Act.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the SEC’s motion to appoint a Chapter 11 trustee did not constitute “bringing an action” under the Dodd-Frank Act. The court found that the ordinary meaning of “action brought” refers to initiating a lawsuit or legal proceedings, which did not apply to the SEC’s involvement in the bankruptcy case. The court also rejected the argument that the SEC’s actions in the bankruptcy case were a continuation of its enforcement strategy. Consequently, the court denied the petitions for review, upholding the SEC’s award calculations. View "Barr v. SEC" on Justia Law

Two defendants, Arturo Cuellar ("AC") and Ricardo Quintanilla, were involved in a scheme to bribe city commissioners in Weslaco, Texas, to secure contracts for an infrastructure project. The bribes were intended to influence the awarding of contracts to Camp Dresser & McKee (CDM) and Briones Consulting and Engineering, Ltd. Quintanilla bribed Commissioner Gerardo Tafolla, while AC bribed Commissioner John Cuellar (JC). Leo Lopez, a consultant for CDM and Briones, facilitated the bribes. The scheme involved multiple meetings and payments, with both commissioners taking actions to favor CDM and Briones. The city paid approximately $42.5 million to CDM, Briones, and LeFevre, with Lopez distributing funds to AC and Quintanilla.The United States District Court for the Southern District of Texas convicted Quintanilla and AC of various federal offenses, including conspiracy to commit honest-services wire fraud, honest-services wire fraud, federal program bribery, conspiracy to launder monetary instruments, and money laundering. Quintanilla was sentenced to 200 months in custody, while AC received 240 months. Both were also ordered to pay fines, special assessments, restitution, and forfeiture amounts. The defendants appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the convictions and sentences. The court addressed several issues raised by the defendants, including claims of constructive amendment of the indictment, sufficiency of the indictment, recusal of the district judge, and evidentiary rulings. The court found that the government did not constructively amend the indictment and that the evidence supported the convictions. The court also held that the district judge did not need to recuse herself and that the evidentiary rulings were within the court's discretion. The court concluded that the defendants' arguments were either forfeited, not meritorious, or both. View "USA v. Quintanilla" on Justia Law

Juan Jose Paramo, the defendant-appellant, is involved in a legal dispute with Banco Mercantil de Norte, S.A. and Arrendadora y Factor Banorte, S.A. de C.V. (the Banorte Parties). The Banorte Parties allege that Paramo committed large-scale fraud in Mexico and fled to the United States. They are pursuing a civil lawsuit in Mexico and sought discovery in the U.S. under 28 U.S.C. § 1782 to locate and seize Paramo’s assets. The Banorte Parties filed an ex parte request for discovery assistance, which the district court granted, authorizing subpoenas for Paramo and two other individuals.The United States District Court for the Southern District of Texas granted the Banorte Parties' petition and authorized the subpoenas. Paramo filed a motion to quash the subpoenas, arguing that the discovery request was overly broad and that the Intel factors favored him. The district court denied Paramo’s motion in a brief order without waiting for his reply or holding a hearing. Paramo appealed the decision, arguing that the district court failed to provide reasoning for its denial and violated local rules by not allowing him to file a reply.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court abused its discretion by failing to provide any reasoning for its decision to deny Paramo’s motion to quash. The Fifth Circuit emphasized that district courts must explain their decisions when granting or denying motions to quash § 1782 subpoenas to allow for effective appellate review. Consequently, the Fifth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to provide a reasoned decision. The court did not address the substantive arguments regarding the Intel factors or the scope of the discovery request. View "Banco Mercantil de Norte, S.A. v. Paramo" on Justia Law