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

In June 2023, the defendant was arrested for selling a substantial quantity of methamphetamine to a government informant in two separate transactions, leading to a two-count federal indictment for drug trafficking offenses. Before pleading guilty to one count (with the other dismissed as part of a plea agreement), the defendant successfully petitioned a Mississippi state court to expunge a 2006 felony marijuana conviction. The expungement order, granted without a hearing or any findings of rehabilitation, restored the defendant to his pre-arrest legal status but preserved certain nonpublic records and did not address potential use in later proceedings.During sentencing in the United States District Court for the Northern District of Mississippi, the presentence report included the expunged marijuana conviction in the defendant’s criminal history, resulting in a higher offense level and a calculated guideline range of 262 to 327 months. The defendant objected, arguing the expunged conviction should not count. The district court overruled this objection, finding the expungement did not meet federal Sentencing Guidelines criteria, particularly as it was not based on innocence or legal error, and was instead a mechanism to restore civil rights. The court also questioned the circumstances of the expungement but ultimately imposed a below-guidelines sentence of 180 months, stating it would have imposed the same sentence even if the prior conviction had not been counted.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court properly included the expunged conviction in the criminal history calculation. The Fifth Circuit clarified that, under the Sentencing Guidelines, only convictions expunged due to innocence or legal error are excluded; expungements granted for other reasons, such as restoring civil rights, must be counted. The court affirmed the sentence. View "United States v. Payne" on Justia Law

A Louisiana limited liability company (LLC) with a sole member voluntarily dissolved in April 2024 and subsequently had its Texas registration terminated in May 2024. Prior to dissolution, the LLC had developed a bid strategy for certain oilfield assets and shared confidential information with a bank to seek financing. The assets were ultimately acquired by a different bidder, also financed by the same bank, and the LLC alleged that its confidential information was improperly conveyed to the winning bidder. After dissolution, the LLC initiated a lawsuit in July 2024 against the bank and the winning bidder, asserting trade secret misappropriation and breach of contract.In the United States District Court for the Southern District of Texas, the defendants moved for judgment on the pleadings, arguing the LLC lacked capacity to sue due to its prior dissolution. The LLC did not contest its lack of capacity but requested a stay while it sought reinstatement in Louisiana state court. The district court granted judgment on the pleadings for lack of capacity, denied the LLC’s request for a stay, and denied the defendants’ request to seek attorneys’ fees. The court also sealed various filings relating to the mental health of the LLC’s sole member.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s judgment on the pleadings, holding that under Texas law, an entity dissolved prior to suit lacks capacity to file suit, and that Louisiana law does not permit retroactive reinstatement of an LLC dissolved by affidavit to pursue claims known before dissolution but filed after. The Fifth Circuit denied the LLC’s request to certify a question to the Louisiana Supreme Court and affirmed the denial of attorneys’ fees. However, it vacated the district court’s sealing order, remanding for proper balancing of the public’s right of access to court records, as required by precedent. View "Juneau Group v. Vendera Management" on Justia Law

Five individuals residing near a New Orleans hospital brought suit after the hospital moved its helicopter landing pad from a one-story building near the Mississippi River to the top of a new tower in the center of the hospital complex. The plaintiffs, claiming that the new helipad created excessive noise and vibrations, sought a mandatory injunction requiring the hospital to relocate the helipad or otherwise abate the disturbance, as well as damages for nuisance and negligence.The defendants removed the case from state court to the United States District Court for the Eastern District of Louisiana. The district court denied the plaintiffs’ request to remand the case to state court, finding that their subsequent removal of class-action allegations and request to decline supplemental jurisdiction amounted to improper forum shopping. The district court then granted the defendants partial summary judgment, holding that Federal Aviation Administration regulations preempted any permanent injunction to relocate the helipad. The court also dismissed some of the plaintiffs’ claims for damages, but allowed their claims for general nuisance damages to proceed to trial. Before trial, the plaintiffs appealed the order, seeking review of the denial of their request for an injunction.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that it lacked jurisdiction over the interlocutory appeal because the district court’s order did not explicitly deny an injunction and, even if it had the practical effect of denying injunctive relief, the plaintiffs did not show that they satisfied the requirements for interlocutory review under 28 U.S.C. § 1292(a)(1) and Carson v. American Brands, Inc. The appeal was dismissed for lack of jurisdiction. View "Rey v. LCMC Health Care Partners" on Justia Law

Texas law allows certain students, including those who are not lawfully present in the United States, to qualify for in-state tuition rates at public colleges if they meet residency requirements. The Texas Education Code provisions in question—sections 54.051(m) and 54.052(a)—permit illegal aliens who establish residency in Texas to pay discounted tuition, while out-of-state U.S. citizens must pay higher rates. The United States brought suit against Texas, alleging that these provisions violate federal law, specifically 8 U.S.C. § 1623(a), which bars states from granting postsecondary education benefits to illegal aliens based on residency unless all U.S. citizens and nationals are eligible for the same benefit regardless of residency.The United States District Court for the Northern District of Texas approved a consent judgment permanently enjoining Texas from enforcing the challenged provisions. After judgment, advocacy groups, a community college, and a student moved to intervene and sought to vacate or alter the judgment, arguing the provisions were not preempted by federal law. The district court denied intervention, reasoning it was legally futile because 8 U.S.C. § 1623(a) expressly preempts the Texas statutes.The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed. The court held that intervention was futile because federal law expressly preempts the Texas provisions, barring states from conferring in-state tuition benefits to illegal aliens based on residency unless all U.S. citizens and nationals may receive the same benefit without regard to residency. The court also dismissed the remaining claims for lack of appellate jurisdiction, as the movants were not parties to the case and therefore had no right to appeal the consent judgment. View "USA v. Texas" on Justia Law

Police officers in Houston attempted to arrest an individual, Jalen Randle, pursuant to three outstanding felony warrants. During their operation, officers pursued Randle as he entered a vehicle. After the police immobilized the car, Randle exited, briefly returned to the vehicle to retrieve a closed bag, and then turned. Within seconds, Officer Shane Privette exited his vehicle, drew his firearm, and commanded Randle to show his hands. Before finishing his warning, Privette fired one fatal shot. The bag Randle retrieved was later found to contain a firearm. Randle was pronounced dead after being taken to the hospital.Randle’s estate and family sued various parties, including Officer Privette, the Houston Police Chief, and the City of Houston, alleging excessive force, supervisory liability, and municipal liability under Monell. The United States District Court for the Southern District of Texas converted motions to dismiss into motions for summary judgment after limited discovery, specifically to evaluate Privette’s qualified immunity claim. The district court granted summary judgment to Privette, holding that his actions were objectively reasonable under the Fourth Amendment and that he was entitled to qualified immunity because there was no clearly established law prohibiting his conduct at the time.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s ruling de novo. The court focused on the second prong of the qualified immunity analysis—whether Randle’s right was clearly established—and held that plaintiffs failed to cite controlling authority or a robust consensus of persuasive authority with sufficiently similar facts to place the constitutional question “beyond debate.” The appellate court concluded that Privette was entitled to qualified immunity and therefore affirmed the district court’s grant of summary judgment. View "Searles v. City of Houston" on Justia Law

Sarah Budd, employed by SkyWest Airlines at Dallas-Fort Worth International Airport, was subjected to severe and persistent sexual harassment by coworkers and a supervisor, including degrading comments, sexual jokes, and references to prostitution and rape. Despite reporting these incidents to her supervisor, the harassment continued and escalated, resulting in significant emotional distress and physical symptoms for Budd. Following an internal investigation by SkyWest that resulted in minimal disciplinary action, Budd elected to take early retirement during the COVID-19 pandemic, fearing the work environment would not improve.The Equal Employment Opportunity Commission filed suit on Budd’s behalf in the United States District Court for the Northern District of Texas, alleging violations of Title VII. After trial, a jury found that Budd had been harassed based on her sex and that SkyWest had failed to take prompt remedial action, but did not find retaliation. The jury awarded Budd both compensatory and punitive damages. SkyWest moved for a new trial based on evidentiary objections, challenged the jury instructions regarding mitigation of emotional damages, and sought judgment as a matter of law on punitive damages. The district court denied these motions.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the text messages admitted at trial were properly admitted as present sense impressions or statements of then-existing mental and physical condition under the Federal Rules of Evidence. The court further held that Title VII plaintiffs are not required to mitigate damages for emotional distress, as neither statutory text nor well-established common law supports such a requirement. Finally, the court concluded that sufficient evidence supported the jury’s punitive damages award, as at least one manager acted with malice or reckless indifference and SkyWest failed to demonstrate a good-faith effort to address the harassment. View "EEOC v. SkyWest Airlines" on Justia Law

On a hot day in Texas in 2019, Darren Boykin fled from campus police and, after a half-mile chase, was apprehended by law enforcement officers. During and after the arrest, Boykin complained of being unable to breathe, but officers attributed his symptoms to exhaustion from running, not knowing that he had sickle cell trait—a condition that can cause sudden death after intense physical exertion. Officer Hobbs responded to Boykin’s complaints by increasing the air conditioning. Sergeant Scott arrived after Boykin was already in the patrol car and relied on the assessment of the other officers. Officer Weaver transported Boykin to jail; during the trip, Boykin’s condition worsened, and he lost consciousness. Upon arrival at the jail, Weaver found Boykin unresponsive, began resuscitation, and called for emergency help. Boykin ultimately died at the hospital.Boykin’s family and estate sued the officers in the United States District Court for the Eastern District of Texas under 42 U.S.C. § 1983, alleging deliberate indifference to serious medical needs. The district court granted summary judgment to the officers, finding that they were entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. The appellate court held that there was insufficient evidence for a reasonable jury to find that Hobbs or Scott had actual knowledge of a serious medical risk to Boykin; at most, they misinterpreted his symptoms as exhaustion. Regarding Weaver, the court found that a jury could infer she became aware of Boykin’s medical distress during transport. However, the court concluded that, as of 2019, it was not clearly established law that an officer in Weaver’s position was required to immediately secure aid for a detainee losing consciousness during transport. Therefore, the Fifth Circuit affirmed summary judgment for all three officers on qualified immunity grounds. View "Thorpe v. Weaver" on Justia Law

Delfin LNG sought approval to construct and operate a deepwater liquefied natural gas export facility in the Gulf of America, consisting of onshore infrastructure in Louisiana and floating offshore vessels. The Maritime Administration (MARAD), after extensive environmental review and public comment, initially approved the project in 2017. Over subsequent years, Delfin altered key aspects of the project, including its design and financing. MARAD determined these changes required further review and asked Delfin to submit an amended application, which Delfin did not do. In 2025, following a presidential executive order, MARAD concluded that the modifications would not cause significantly different environmental impacts and issued the license.Three environmental organizations challenged MARAD’s decision in the United States Court of Appeals for the Fifth Circuit. They argued MARAD violated the Deepwater Port Act by not requiring an amended application and additional public comment, the National Environmental Policy Act by not preparing a supplemental environmental impact statement, and the Administrative Procedure Act by issuing a license after finding the prior approval was insufficient. They requested the court vacate MARAD’s licensing decision.The United States Court of Appeals for the Fifth Circuit found that none of the petitioners demonstrated Article III standing. The court held that the organizations failed to identify a member who suffered a concrete and particularized injury fairly traceable to MARAD’s licensing decision. The declarations submitted did not show a personal and project-specific harm, nor did they establish a sufficient geographic nexus to the affected area. As a result, the court concluded it lacked jurisdiction to consider the merits and denied the petition for review. The main holding is that, in the absence of standing, the court cannot reach the substantive environmental or procedural claims. View "Center for Bio Diversity v. TRAN" on Justia Law

A laboratory testing company, Boston Heart Diagnostics (BHD), and two rural Texas hospitals, Little River Health Care and Integrity Transitional Hospital, entered into arrangements where affiliated physicians referred blood tests to the hospitals, which then billed payors, including Medicare, at advantageous rates. The hospitals used Management Service Organizations (MSOs) as intermediaries to recruit and pay physicians, and BHD’s sales team—including several defendants—facilitated these relationships. Evidence at trial showed MSOs were used to provide kickbacks to physicians based on referral volume, disguised through sham contracts, resulting in unusually high revenues for BHD. The defendants included BHD’s CEO, vice president of sales, and sales representatives, who were involved in managing and growing these partnerships.A federal grand jury indicted eighteen individuals for conspiracy to commit illegal remunerations in violation of the Anti-Kickback Statute (AKS) and 18 U.S.C. § 371. Five defendants proceeded to a joint jury trial in the United States District Court for the Eastern District of Texas. The government presented testimony from co-conspirators and documentary evidence to show the existence of the scheme and the defendants’ knowledge and participation. The jury found all five guilty of conspiracy. The court denied post-trial motions for acquittal or a new trial, sentenced the defendants, and four of them appealed.The United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the evidence de novo and other claims under deferential standards. The court affirmed all convictions, holding that a rational jury could find beyond a reasonable doubt that the defendants knowingly and willfully joined a conspiracy to pay illegal kickbacks to induce referrals for federally insured patients. The court also held there was sufficient evidence of a federal nexus and no error in the district court’s handling of jury notes or instructional refusals. The convictions and sentences were affirmed. View "USA v. Theiler" on Justia Law

A defendant pleaded guilty to transporting child pornography pursuant to a written plea agreement with the government. In exchange for the dismissal of two more serious charges—sexual exploitation of a minor and possession of child pornography—the defendant admitted guilt to the transportation offense. The plea agreement included an appellate waiver, allowing appeals only for claims of ineffective assistance of counsel. The defendant confirmed in court that he understood the agreement’s terms, including the maximum penalties and mandatory restitution. At sentencing, the court imposed 240 months’ imprisonment, lifetime supervised release, and $17,500 in restitution to two victims.The United States District Court for the Southern District of Texas accepted the defendant's guilty plea and sentenced him according to the statutory maximum and mandatory minimums outlined in the plea agreement. The court also conducted a joint change-of-plea hearing for the defendant and another individual, advising both about appellate rights. The presentence report attributed 3,092 images of child pornography to the defendant, and the court considered victim-impact statements and restitution requests before issuing its sentence. The defendant did not object to the restitution calculation at sentencing.On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant argued that the district court misled him regarding his appellate rights during the plea colloquy, imposed unreasonable prison and supervised release terms, and failed to properly analyze causation and apportionment for restitution as required by Paroline v. United States. The Fifth Circuit held that the appellate waiver was knowing and voluntary, barring challenges to the conviction, sentence, and restitution. The court found no plain error in the district court’s advisement or restitution calculation and affirmed the judgment. View "USA v. Quintanilla" on Justia Law