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

Employees at a Starbucks store in Sylmar, California, engaged in union organizing activities during 2022. Several conversations between store managers and employees occurred regarding the unionization process, pay and benefit increases, and working conditions. Employees reported statements by managers suggesting that certain benefits would be paused or lost due to union negotiations, that unionization would not improve conditions, and that other jobs offered better pay. One employee, Untaran, was interrogated about his union support and subsequently terminated, with conflicting accounts regarding the reasons for his discharge.After a union election where a majority voted against representation, the union filed objections based on Untaran’s termination and management statements. An Administrative Law Judge for the National Labor Relations Board (NLRB) found violations of the National Labor Relations Act (NLRA), including coercive threats, interrogation, and unlawful discharge, and ordered remedies such as reinstatement, back pay, compensatory damages, and a new election. The NLRB adopted some findings and reversed others, particularly expanding the findings regarding coercive interrogation and threats.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court upheld the NLRB’s findings and enforcement orders regarding one coercive threat against Pichardo, the threat against Untaran, and Untaran’s coercive interrogation claim, finding these supported by substantial evidence. However, the court denied enforcement for the NLRB’s order regarding Untaran’s unlawful discharge claim and the coercive threat claims involving Sosa and Ramirez, as they lacked substantial evidence. The court dismissed Starbucks’s appeal regarding the order for a second union election, citing lack of jurisdiction over representation proceedings consolidated with unfair labor practice cases. View "Starbucks v. NLRB" on Justia Law

A deputy sheriff in Medina County, Texas, stopped a vehicle that had been reported stolen and possibly involved in an armed robbery. After detaining the driver, a seventeen-year-old named Branden Sanchez, the officer handcuffed him and placed him in the back seat of his cruiser. Over the course of approximately 50 minutes, Sanchez became disruptive, repeatedly yelling and kicking the cruiser’s doors and demanding to be taken to jail. Although surrounded by multiple officers and restrained by handcuffs and a seatbelt, Sanchez resisted orders to sit properly. In response to his continued noncompliance, the deputy forcibly repositioned Sanchez in the seat and later discharged a high-velocity pepper spray device into Sanchez’s face from a distance shorter than the manufacturer’s recommended minimum, resulting in permanent blindness in one eye.Sanchez filed suit in the United States District Court for the Western District of Texas under 42 U.S.C. § 1983, alleging excessive force in violation of his Fourth Amendment rights. The deputy moved to dismiss the complaint, asserting qualified immunity. The district court denied the motion, finding that Sanchez had plausibly alleged facts showing a violation of clearly established law regarding the use of excessive force against a restrained and non-threatening suspect.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of qualified immunity de novo. The Fifth Circuit concluded that, taking the facts in the light most favorable to Sanchez, he adequately alleged both a constitutional violation and that the right was clearly established at the time. The court determined that precedent would have put a reasonable officer on notice that using pepper spray in this manner against a restrained, outnumbered, and non-threatening suspect was unlawful. Accordingly, the Fifth Circuit affirmed the district court’s denial of qualified immunity. View "Sanchez v. Nunemaker" on Justia Law

A registered nurse, who is a black woman and naturalized U.S. citizen from Ghana, began working at a healthcare system in Texas and alleged frequent discrimination and harassment by co-workers, including mockery of her accent and food, derogatory comments about black employees, and preferential treatment of Filipino employees. She reported these incidents to supervisors, but claims their response was inadequate. After further complaints, she alleges retaliation through informal and formal disciplinary actions and the extension of her probation period. She was later injured in a car accident, took medical leave, and upon seeking treatment at a hospital operated by the same employer during a hurricane lockdown, had contentious interactions with staff, but ultimately received care. When she tried to return to work, she requested refresher orientation and additional training, but after further delays and lack of response, she resigned, citing discrimination and retaliation.She subsequently filed two charges with the Equal Employment Opportunity Commission. The first charge, encompassing events through September 2017, was timely; the second, covering her resignation and later events, was untimely. In May 2021, she sued her employer for discrimination, hostile work environment, retaliation under Title VII and Section 1981, and disability discrimination under the ADA. The United States District Court for the Southern District of Texas adopted a magistrate judge’s recommendation granting summary judgment to the employer on all claims.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed summary judgment for the employer on most claims. However, it reversed the grant of summary judgment on the plaintiff’s Title VII and Section 1981 hostile-work-environment claims, holding that there was a genuine dispute of material fact as to whether the conduct was severe or pervasive and whether the employer’s response was adequate. The court remanded those claims for further proceedings, limiting them to facts alleged in the plaintiff’s timely EEOC charge. View "Brenyah v. Columbia Hospital" on Justia Law

Several property owners in New Braunfels, Texas, challenged a city zoning ordinance that prohibits short-term rentals in residential districts. The ordinance, originally enacted in 2006 and amended in 2011, was in place prior to the appellants’ purchase of their properties. Despite knowing about the restrictions, the appellants either engaged in or sought to engage in short-term rental activities and, after being denied zoning changes to permit such use, filed suit against the city. Their claims alleged the ordinance violated the Due Process and Equal Protection Clauses of both the United States and Texas Constitutions.The United States District Court for the Western District of Texas initially dismissed the appellants’ claims under Rule 12(b)(6). The United States Court of Appeals for the Fifth Circuit, in a prior decision, vacated and remanded, allowing the appellants to proceed to discovery. After discovery, both parties moved for summary judgment. The district court again ruled in favor of the city, granting summary judgment on all claims. The appellants then sought review of this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that Texas law does not recognize a protected property interest in the right to lease one’s home on a short-term basis, which is required for a due process claim. It further found that the ordinance’s restrictions on short-term rentals survive rational-basis review under the Equal Protection Clause, as the city’s goal of preserving the residential character of neighborhoods is a legitimate government interest, and the line drawn between short-term and longer-term rentals was not arbitrary. Accordingly, the court found no constitutional violation and affirmed the summary judgment in favor of the city. View "Marfil v. City of New Braunfels" on Justia Law

After law enforcement arrested the defendant for unlawfully discharging a firearm, they executed a search warrant at his home. During the search, officers seized multiple firearms, suspected silencers, and other related paraphernalia. The Bureau of Alcohol, Tobacco, Firearms, and Explosives evaluated the items and determined the suspected silencers met the statutory definition of devices designed for silencing, muffling, or diminishing the report of a firearm. The defendant admitted to manufacturing and possessing the silencers.A federal grand jury charged the defendant with possession of unregistered firearms, specifically silencers, in violation of 26 U.S.C. § 5861(d), and possession of a firearm without a serial number under 26 U.S.C. § 5861(i). He moved to dismiss the indictment, arguing that both statutes violated the Second Amendment facially and as applied to him. The United States District Court for the Western District of Louisiana denied the motion, finding silencers to be “dangerous and unusual weapons” not protected by the Second Amendment. The defendant then entered a conditional guilty plea, reserving his right to appeal the constitutional issue, and was sentenced to twenty-four months in prison and three years of supervised release.Reviewing the appeal, the United States Court of Appeals for the Fifth Circuit applied de novo review to the preserved constitutional questions. The court acknowledged that, per Supreme Court precedent, silencers qualify as Second Amendment “Arms.” However, in light of United States v. Peterson, 161 F.4th 331 (5th Cir. 2025), the Fifth Circuit held that the National Firearms Act’s shall-issue regime for silencer registration is presumptively lawful unless a challenger shows it has been put toward abusive ends, such as through exorbitant fees or lengthy delays. Because the defendant did not allege such abuse, the court held that § 5861(d) did not violate his Second Amendment rights and affirmed the conviction. View "USA v. Comeaux" on Justia Law

A maintenance worker was injured when a small derrick tipped over during work on a defective transformer. Two years after the incident, the injured individual and his spouse filed suit against the derrick’s manufacturer and several corporate entities that leased the equipment to the worker’s employer. The complaint was filed on the last day permitted by the Texas statute of limitations. Plaintiffs received service citations the next day, and forwarded them to a process server three days later. Service was completed about fifty days after filing, with delays attributed to confusion over defendants’ identities and addresses, as well as disruptions caused by a courthouse fire in an unrelated case involving plaintiffs’ counsel.After defendants were served, they removed the case to the United States District Court for the Southern District of Texas. The district court dismissed the claims against the manufacturer for insufficient diligence in service and granted summary judgment for the corporate defendants. The district court found that plaintiffs had waited too long at several points—three days before forwarding citations, several weeks before following up with the process server, and additional days before clarifying instructions—thus concluding that plaintiffs failed to exercise sufficient diligence as required by Texas law.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the district court applied a more demanding standard than Texas law requires. Under Texas law, a plaintiff must show ordinary diligence in effecting service after timely filing suit. The appellate court found that plaintiffs’ explanations for the short delays, including handling a complex service task involving multiple corporate defendants and temporary distractions from an unrelated courthouse fire, were sufficient to raise a genuine factual dispute regarding diligence. The Fifth Circuit reversed the district court’s dismissal and summary judgment, and remanded the case for further proceedings. View "Larkins v. S.D.P. Manufacturing" on Justia Law

A freight service company chartered two barges to a third party, Work Cat, under an agreement that included a “no-lien” clause, prohibiting the charterer from incurring liens on the barges. Work Cat, in turn, chartered two tugboats from another company to tow the barges. While Work Cat initially paid for the tug services, it defaulted on the majority of payments and eventually filed for bankruptcy. The tug owner, seeking to recover unpaid invoices, filed maritime lien notices against the barges and demanded payment from the original barge owner, who refused, arguing that the “no-lien” clause prevented such a lien.The United States District Court for the Eastern District of Louisiana held a bench trial. It determined that the tug owner had valid maritime liens against both barges for the value of towage services provided, but excluded the costs of fuel and lubricants. The district court initially awarded attorney’s fees to the tug owner but later reversed this decision, ordering each party to bear its own legal costs. Both parties appealed, challenging the existence, scope, and value of the liens, as well as the award of attorney’s fees.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It held that a maritime lien attached to the barges because the tug owner provided necessary services without actual knowledge of the “no-lien” clause at the time the towage contract was executed. The court clarified that actual knowledge of such a clause, not constructive knowledge or a duty to investigate, is required to defeat a maritime lien under current law. The value of the lien properly included all towage services but excluded fuel and lubricant costs. The appellate court also found no abuse of discretion in the district court’s denial of attorney’s fees and its award of prejudgment interest. View "Trailer Bridge v. LA Intl Marine" on Justia Law

James Baldemoro pleaded guilty to possession of child pornography in 2014 and received a statutory maximum sentence of ten years in prison followed by ten years of supervised release. After completing his prison term, Baldemoro began supervised release but twice violated its conditions. For each violation, the United States District Court for the Southern District of Texas revoked his supervised release and imposed a six-month term of reimprisonment, followed by a new period of supervised release. At each revocation hearing, Baldemoro argued that having already served the statutory maximum prison sentence for his offense, any further imprisonment was unlawful.The district court rejected Baldemoro’s arguments both times, ruling that reimprisonment following revocation of supervised release was authorized under 18 U.S.C. § 3583(e)(3), regardless of whether it resulted in more total time in custody than the statutory maximum for the initial offense. Baldemoro appealed both revocation sentences. The United States Court of Appeals for the Fifth Circuit consolidated the appeals and considered whether his challenges were moot and whether his new sentences were lawful.The Fifth Circuit held that Baldemoro’s appeals were not moot because a favorable decision could allow him to seek a reduction or termination of his supervised release. On the merits, the court held that 18 U.S.C. § 3583(e)(3) authorizes reimprisonment beyond the statutory maximum for the underlying offense, limited only by the felony class, not the maximum sentence for the conviction. The court also found that such reimprisonment does not violate the Fifth or Sixth Amendments, as the constitutional protections involved in criminal prosecutions do not apply to supervised release revocation proceedings. The judgment of the district court was affirmed. View "USA v. Baldemoro" on Justia Law

The United States initiated a lawsuit against Dr. Dongxin Ma and Ma Acupuncture Center, P.C., alleging violations of the False Claims Act. The government claimed that the defendants submitted inflated reimbursement requests for acupuncture services provided to veterans, resulting in improper payments from the Department of Veterans Affairs. The United States sought substantial damages and civil penalties, while the defendants denied liability and asserted they acted in good faith.Following mediation, the parties reached significant agreement regarding the terms of settlement. The mediation resulted in an oral agreement that included payment by the defendants of $2.3 million over 42 months, an initial $100,000 payment, dismissal and release of civil claims by the government, reasonable efforts by Dr. Ma to sell certain property, and the government’s right to place liens if obligations were not met. The United States filed a notice of settlement and submitted a written agreement containing additional standard terms. The defendants, later represented by new counsel, contested the validity of the settlement, arguing that the written agreement included material terms not discussed at mediation and that Dr. Ma had not authorized settlement above $1 million.The United States District Court for the Western District of Texas held an evidentiary hearing, ultimately concluding that the parties had orally agreed to all material terms at mediation and that the additional terms in the written agreement were immaterial. The court amended its judgment to enforce only the material terms agreed orally. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision for abuse of discretion and affirmed. The Fifth Circuit held that the district court did not abuse its discretion in enforcing the oral settlement agreement, finding that all material terms were agreed to at mediation and that additional terms in the written agreement were not material. The court also found that the defendants had forfeited certain arguments on appeal. View "USA v. Ma" on Justia Law

Three named plaintiffs, all working for Schlumberger in oilfield drilling positions, challenged their employer’s compensation system under the Fair Labor Standards Act. Their pay structure included both a fixed, predetermined salary paid biweekly and substantial additional daily or activity-based payments, which often comprised the majority of their earnings. The plaintiffs regularly worked more than forty hours per week but did not receive overtime pay. They brought a collective action, arguing that their hybrid compensation arrangement did not meet the requirements for the Fair Labor Standards Act’s “salary basis” exemption, and therefore they were entitled to overtime pay.The United States District Court for the Western District of Texas denied Schlumberger’s motion for partial summary judgment, finding that material factual disputes prevented judgment as a matter of law on whether the plaintiffs were paid on a salary basis. The court allowed notice to a proposed collective of Directional Drillers but denied notice to another group, and it later certified an interlocutory appeal due to the unsettled state of the law regarding hybrid pay schemes.On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of summary judgment de novo. The Fifth Circuit held that the hybrid compensation plan, which included a guaranteed, predetermined salary paid on a weekly or less frequent basis, satisfied the regulatory requirements for the salary basis exemption under 29 C.F.R. § 541.602(a), regardless of additional day-based or incentive payments. The court reversed the district court’s decision and ordered summary judgment for Schlumberger as to the named plaintiff Guilbeau, finding him overtime-exempt. However, the court remanded the case for further proceedings regarding other collective members, as their exemption status required additional individualized determinations. View "Guilbeau v. Schlumberger Technology" on Justia Law