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

Albert Hayes worked as an IT systems administrator for GStek, Inc., a contractor providing services for the U.S. Army at Fort Polk. After the COVID-19 pandemic, Hayes was required to return to in-person work. He subsequently received diagnoses of Autism, Major Depressive Disorder, and Social Anxiety Disorder. Hayes requested permission to telework as a reasonable accommodation for his disabilities. The Army, which controlled conditions for contractors at Fort Polk, determined that full-time telework was not in its best interests and denied the request. GStek allowed Hayes to telework two to three days per week, but after a mental health crisis and continued absenteeism, Hayes was terminated.Hayes pursued administrative remedies against the Army under the Rehabilitation Act, but his claims were dismissed because he was not an Army employee and had not timely pursued administrative procedures. He did not appeal that dismissal. Hayes then filed a charge of discrimination against GStek with the Equal Employment Opportunity Commission and, after receiving a right-to-sue notice, sued GStek in the United States District Court for the Western District of Louisiana, bringing claims for failure-to-accommodate, disability discrimination, and retaliation under the Americans with Disabilities Act (ADA). The district court granted GStek’s motion for judgment on the pleadings, finding that Hayes received a reasonable accommodation, was not a qualified individual under the ADA, and failed to establish prima facie cases for discrimination or retaliation.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that in-person attendance was an essential function of Hayes’s job and telework was not a reasonable accommodation under the circumstances. Hayes was not a qualified individual because he could not perform the essential functions of his position, even with accommodations. As a result, his claims for failure-to-accommodate, discrimination, and retaliation under the ADA all failed. View "Hayes v. GStek" on Justia Law

Trojan Battery, a well-established manufacturer of golf cart batteries with valuable trademark rights in the “TROJAN” name and related marks, sued Golf Carts of Cypress and Trojan EV. The defendants, owned by the same individual, began selling golf carts under the “TROJAN-EV” brand, which led to alleged confusion among dealers and customers about the origin or affiliation of the products. Trojan Battery sent a cease-and-desist letter, but the defendants continued their use of the TROJAN-EV mark. The evidence showed that both companies operated within the golf industry, used similar advertising channels, and targeted the same customer base.The United States District Court for the Southern District of Texas held a bench trial. The district court found the defendants liable for trademark infringement and unfair competition under the Lanham Act and Texas law, based on a likelihood of confusion between the marks. The court awarded Trojan Battery the defendants’ profits as a remedy and issued a permanent injunction against further infringement. The district court also rejected the defendants’ post-trial motions and denied their request to amend the findings of fact and conclusions of law. Defendants appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s liability judgment and the award of profits, finding no clear error in the determination that there was a likelihood of confusion and that disgorgement of profits was warranted. However, the appellate court vacated the permanent injunction, holding that it was overbroad because it extended beyond the golf cart and battery markets, where confusion was likely, to unrelated products and markets. The case was remanded for the district court to narrow the scope of the injunction. View "Trojan Battery v. Golf Carts of Cypress" on Justia Law

The case concerns an asylum seeker from El Salvador who entered the United States without authorization in 2022. He sought asylum, testifying that he had been forced into the MS-13 gang, later allowed to leave but forcibly tattooed, and had suffered torture and threats in El Salvador due to his gang affiliation. An Immigration Judge denied his requests for relief and ordered removal. During his appeal, the Department of Homeland Security inadvertently disclosed his personal information online. The Board of Immigration Appeals affirmed the removal order but remanded the case for further proceedings on his eligibility for deferral of removal. His counsel later withdrew all applications for relief, claiming he was a Mexican citizen, and he was ordered removed to Mexico or, alternatively, El Salvador. Proceeding without counsel, he appealed again, contesting the withdrawal of his applications, but the Board dismissed his appeal.He subsequently filed a motion to reopen his proceedings, arguing that new evidence—specifically, the high-profile arrest and extradition of his father-in-law, a former MS-13 leader—constituted changed country conditions increasing his risk if returned to El Salvador. He also requested equitable tolling of the filing deadline, citing ineffective assistance of counsel, his pro se status, and other obstacles.The Board of Immigration Appeals denied the motion to reopen as untimely, finding no evidence of materially changed country conditions, only a change in personal circumstances. The Board also found no basis for equitable tolling, as he failed to demonstrate that counsel’s ineffectiveness prevented timely filing. The petitioner then sought review by the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit held that the Board did not abuse its discretion in denying both the exception for changed country conditions and equitable tolling. The court denied the petition for review. View "Prado-Majano v. Blanche" on Justia Law

A catastrophic storm in March 2016 caused unprecedented rainfall in the Sabine River basin, leading the operators of the Toledo Bend Dam—jointly managed by the Sabine River Authority of Texas and the Sabine River Authority, State of Louisiana—to open nine spillway gates. This action released significant amounts of water into the Sabine River over several weeks. Downriver landowners experienced extensive flooding and property damage. More than 700 landowners brought suit, alleging that the dam operators’ actions constituted a compensable taking of their property under the Fifth Amendment.The case began in the United States District Court for the Eastern District of Texas, where the defendants raised several defenses, including sovereign immunity, which was litigated and ultimately denied. Discovery disputes arose over the admissibility and timeliness of the plaintiffs’ expert affidavits and reports, which were found to rely heavily on an untested graduate thesis. The magistrate judge struck the challenged affidavits as untimely, and the plaintiffs did not object. Later, the district court granted summary judgment for the defendants, finding the plaintiffs had not produced sufficient admissible evidence to create a genuine dispute of material fact as to whether the dam’s operation caused the flooding, nor that a taking had occurred. The court also found the necessity doctrine might shield the defendants but did not decide the case on that ground.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the lower court’s decisions. It held that the district court did not abuse its discretion in excluding the untimely expert affidavits. Affirming summary judgment, the Fifth Circuit found that the plaintiffs had failed to present sufficient evidence of causation—specifically, that the dam’s operation, rather than the unprecedented storm itself, caused additional flooding beyond what would have occurred without the dam. The judgment of the district court was affirmed. View "Bonin v. Sabine River Authority" on Justia Law

A sixteen-year-old girl disappeared from Floresville, Texas in October 2023. Police discovered that she had communicated online with Jayden Douglas Richard Vacchino before her disappearance. The communications revealed Vacchino’s intention to take her from Texas to Louisiana for sexual purposes. Investigators found evidence that Vacchino’s phone was near the victim’s house on the night she went missing, and security footage confirmed his car in the area. Two days later, authorities located Vacchino and the victim together in Shreveport, Louisiana, where he was arrested.Vacchino pleaded guilty in the United States District Court for the Western District of Texas to transporting a minor interstate with intent to engage in criminal sexual conduct under 18 U.S.C. § 2423(a). At the sentencing hearing, the district court did not explicitly adopt the presentence report but imposed a sentence of 260 months in prison, 15 years of supervised release, a $100 special assessment, and a $25,000 fine. The court recommended sex counseling treatment during incarceration and stated it would impose “standard conditions” of supervised release “plus the sex offender conditions.” The written judgment, however, included additional special conditions from the presentence report and omitted the specific recommendation for sex counseling treatment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed several discrepancies between the oral sentence and the written judgment. The court held that mandatory supervised release condition 10, which required notification of economic changes, conflicted with the oral pronouncement and must be vacated. The court affirmed the other challenged conditions, finding that they either reflected the district court’s intent or clarified ambiguities. The Fifth Circuit also ordered correction of the written judgment to include the oral recommendation for sex counseling treatment. The judgment was thus vacated in part, affirmed in part, and remanded for further proceedings. View "USA v. Vacchino" on Justia Law

A seaman was severely injured while working on an offshore supply vessel operated by his employer. Following his injury, the employer provided both mandatory and supplemental benefits, including housing and transportation. Six months after the incident, the employer’s executives presented the seaman with an agreement offering continued supplemental benefits in exchange for his commitment to arbitrate any future claims against the company. The agreement included a delegation clause stating that any disputes about the validity, interpretation, or application of the agreement would be resolved by an arbitrator. The seaman signed, acknowledging he had the opportunity to consult an attorney but later alleged he felt pressured and feared losing benefits if he did not sign.The seaman filed suit in the United States District Court for the Eastern District of Louisiana, alleging negligence and seeking a declaration that the agreement and its arbitration provisions were invalid due to fraud, duress, and his medical condition. The employer moved to compel arbitration and to stay the litigation, arguing that the delegation clause required an arbitrator to decide issues of enforceability. The district court denied the motion without prejudice and allowed limited discovery on the enforceability of the agreement, concluding it must decide if a valid arbitration agreement existed.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred by failing to enforce the delegation clause. The appellate court found the seaman’s arguments challenged the agreement as a whole, not the delegation clause specifically. Under Supreme Court precedent, such challenges must be resolved by an arbitrator when a valid delegation clause exists and is not directly challenged. The Fifth Circuit vacated the district court’s order and compelled arbitration, remanding for further proceedings consistent with this holding. View "Hill v. Jackson Offshore Holdings" on Justia Law

After the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization returned abortion regulation to the states, the Food and Drug Administration (FDA) changed its rules to allow the abortion drug mifepristone to be prescribed online and sent by mail, eliminating the prior requirement for in-person doctor visits. The State of Louisiana, joined by an individual plaintiff, challenged this 2023 regulation (the “2023 REMS”) under the Administrative Procedure Act (APA), arguing that the FDA’s decision was not supported by sufficient data and resulted in illegal abortions and increased Medicaid costs within the state.The United States District Court for the Western District of Louisiana found that Louisiana had standing, was likely to succeed on the merits, and was suffering irreparable harm. However, the district court declined to stay the regulation, reasoning that the balance of equities and public interest favored denying immediate relief. Instead, the district court stayed the litigation to allow the FDA to complete its ongoing review of mifepristone’s safety protocols, which the FDA admitted had previously lacked adequate consideration.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a stay of the 2023 REMS pending appeal was warranted under 5 U.S.C. § 705. The Fifth Circuit concluded that Louisiana was strongly likely to succeed on the merits because the FDA’s removal of the in-person dispensing requirement was arbitrary and capricious, relied on insufficient data, and was inadequately explained. The court further found that Louisiana faced ongoing irreparable harm to its sovereign interests and financial losses. The appellate court determined that neither the FDA’s nor the manufacturers’ interests outweighed Louisiana’s injuries or the public interest, and that a stay of the regulation was appropriate. The court therefore granted Louisiana’s motion for a stay pending appeal. View "Louisiana v. FDA" on Justia Law

A private auditor, hired to review an international consulting company’s immigration practices, alleged that the company engaged in widespread visa fraud. He claimed that, to reduce costs and circumvent stricter requirements, the company wrongfully applied for less expensive visas (L-1A and B-1) for employees who should have received H-1B visas, and then assigned those workers to roles requiring H-1B status. The complaint also asserted that the company underpaid visa-dependent workers, in violation of federal wage regulations, resulting in reduced payroll tax withholding.The United States District Court for the Eastern District of Texas reviewed these claims after the government declined to intervene. The district court dismissed the complaint, holding that the company had no obligation under the False Claims Act (FCA) to pay higher visa fees for visas it never applied for, nor any obligation to withhold additional taxes on wages it never paid. The court reasoned that any duty to pay arose only if the company actually applied for, and was granted, the more expensive visas, or if it paid higher wages to its employees.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal. The Fifth Circuit held that, under the FCA, reverse false claim liability requires a present, established duty to pay money to the government—not a contingent or potential obligation. The court found that federal regulations did not impose an immediate duty on the company to pay higher visa fees or to withhold more in taxes without first applying for the appropriate visas or paying higher wages. Because the complaint did not allege the existence of such an obligation, it failed to state a claim under the FCA. The judgment of the district court was affirmed. View "Palmer v. Tata Consulting Services" on Justia Law

In this case, Texas enacted Senate Bill 4 (S.B. 4) in 2023 to address a significant increase in illegal immigration across its southern border. The law criminalizes certain acts of unlawful entry and reentry, tracking federal immigration statutes, and allows for state judges to order the return of individuals found in violation. Before the law took effect, two nonprofit organizations that provide legal services to immigrants and El Paso County filed suit, seeking to have S.B. 4 declared unlawful and its enforcement enjoined. The nonprofits claimed the law would frustrate their missions and require them to divert resources, while El Paso County alleged it would incur increased costs and suffer a loss of public trust.The United States District Court for the Western District of Texas issued a preliminary injunction, finding that S.B. 4 was likely preempted by federal law and that the plaintiffs had standing to sue, based on the alleged frustration of their missions, resource diversion, and reputational harm. Texas appealed to the United States Court of Appeals for the Fifth Circuit. A divided panel initially affirmed the injunction, heavily relying on Havens Realty Corp. v. Coleman to find organizational standing. However, the Supreme Court subsequently decided FDA v. Alliance for Hippocratic Medicine, which narrowed the circumstances under which organizations can claim standing based on resource diversion.The United States Court of Appeals for the Fifth Circuit, sitting en banc, held that the plaintiffs lacked Article III standing. The court concluded that voluntarily incurring costs, merely adjusting to new laws, or alleging reputational harm do not constitute cognizable injuries. As a result, the Fifth Circuit vacated the preliminary injunction, declining to address the merits of the preemption claim. View "USA v. State of Texas" on Justia Law

Scott Martin operated a business in Harris County, Texas, gathering contact information of criminal defendants from public court records and selling it to private attorneys. His business relied primarily on access to bail bond orders, which contained defendants’ addresses and other contact details. In June 2023, the then-presiding judge of the Harris County Criminal Courts at Law issued an administrative order instructing the district clerk to keep the contents of certain bond orders in misdemeanor cases confidential, making only the title, filing date, and page enumeration available to the public. This significantly reduced the information Martin could access, leading to substantial business losses. Martin unsuccessfully sought reconsideration of the order and then filed suit, asserting constitutional and statutory claims and seeking injunctive relief and damages.The case was heard by the United States District Court for the Southern District of Texas. The defendants, including the district clerk and judges, moved to dismiss, arguing the order did not violate any constitutional right and that they were immune from suit. The district court, after a hearing, granted the motion to dismiss. The court determined that under Los Angeles Police Department v. United Reporting Publishing Corp., Martin’s First Amendment claim failed because the order merely restricted access to government information, not speech. It also found no plausible claim under the Sixth Amendment or Texas law, and concluded Martin had no property interest in the information.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court affirmed the district court’s decision, holding that restricting access to the information in government possession does not violate the First Amendment, and Martin’s other constitutional and state law arguments lacked merit. The court also rejected Martin’s ultra vires claim, finding the judge acted within her statutory authority. Thus, the dismissal was affirmed. View "Martin v. Burgess" on Justia Law