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

Nickolas Trabucco parked at a gas station in Hernando, Mississippi, where Officer Andres Rivera was filling up his patrol car. Rivera approached Trabucco’s car, and after a brief interaction, Trabucco exited his vehicle. The subsequent events, partially obscured by the car, are disputed. Trabucco claimed Rivera grabbed and tackled him without provocation, while Rivera testified that Trabucco resisted and attempted to flee, prompting Rivera to tackle him. Surveillance footage showed Rivera restraining Trabucco, who continued to struggle. Rivera then used a taser on Trabucco, who fell and was subsequently arrested.In the United States District Court for the Northern District of Mississippi, Trabucco sued Rivera under 42 U.S.C. § 1983 for excessive force. The jury found that Rivera used excessive force but was entitled to qualified immunity. Trabucco’s motions for judgment as a matter of law or a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court first addressed whether Trabucco waived his right to challenge the sufficiency of the evidence by not properly moving for judgment as a matter of law. The court found that Trabucco’s actions sufficiently alerted the court and Rivera to the sufficiency issue, allowing the court to consider the evidence. The court then held that Rivera’s use of force was not unreasonable in light of clearly established law, distinguishing this case from precedents like Trammell v. Fruge and Hanks v. Rogers due to factual differences. The court also found no error in the jury instructions and upheld the district court’s denial of Trabucco’s motion for a new trial, concluding that the evidence supported the jury’s verdict. The Fifth Circuit affirmed the district court’s judgment. View "Trabucco v. Rivera" on Justia Law

Spirit AeroSystems, a manufacturer of airplane parts, was issued a Request to Examine (RTE) by the Attorney General of Texas, W. Kenneth Paxton. The RTE statute allows the Attorney General to inspect business records without providing an opportunity for precompliance judicial review. Spirit challenged the statute as facially unconstitutional, arguing it violated the Fourth Amendment by not allowing precompliance review.The United States District Court for the Western District of Texas agreed with Spirit, finding the RTE statute unconstitutional for failing to provide precompliance review and issued a permanent injunction preventing the Attorney General from enforcing the RTEs against Spirit. The court's decision was based on the precedent set by City of Los Angeles v. Patel, which requires an opportunity for precompliance review to avoid Fourth Amendment violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Texas Supreme Court issued a decision in Paxton v. Annunciation House, Inc., which interpreted the RTE statute to include the required opportunity for precompliance review through Texas Rule of Civil Procedure 176.6. This rule allows recipients of administrative subpoenas to seek a protective order before compliance is required.Given the Texas Supreme Court's interpretation, the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with the new interpretation, which now provides the necessary precompliance review to satisfy Fourth Amendment requirements. View "Spirit Aerosystems v. Paxton" on Justia Law

Following Hurricane Ida in 2021, Terrebonne Parish requested assistance from Lafayette Utilities Systems (LUS) to help restore power in Houma, Louisiana. LUS, in turn, requested help from the City of Wilson, North Carolina. Agreements were signed to facilitate emergency assistance, and the City of Wilson dispatched employees to Louisiana. Due to a shortage of hotels in Houma, the employees stayed in Lafayette and commuted daily. Kevin Worrell, a City of Wilson employee, was involved in a vehicle collision while driving from Houma to Lafayette, resulting in injuries to Edward and Linda Breaux and Jessie and Vickie Blanchard.The plaintiffs filed separate negligence lawsuits in Louisiana state court, which were removed to the federal district court in the Western District of Louisiana. The cases were consolidated, and the defendants moved for summary judgment, asserting immunity under the Louisiana Homeland Security and Emergency Assistance and Disaster Act. The district court granted summary judgment, finding statutory immunity, and dismissed the plaintiffs' claims with prejudice. The plaintiffs appealed, challenging the district court's interpretation of the Act's immunity provision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted the need to interpret the Louisiana emergency preparedness law and expressed doubt about its ability to make a reliable Erie guess. Consequently, the court certified two questions to the Louisiana Supreme Court: (1) whether an employee of a city from another state working under an emergency assistance agreement is a "representative" of Louisiana or its political subdivisions, and (2) whether an individual providing emergency assistance is "engaging in emergency preparedness and recovery activities" while commuting from the recovery site to lodging. The Fifth Circuit will resolve the case based on the Louisiana Supreme Court's guidance. View "Breaux v. Worrell" on Justia Law

Petitioners, including various agricultural and trade organizations, challenged the Environmental Protection Agency (EPA) over a rule that set an equation for calculating vehicle fuel economy, specifically the "Ra factor." They argued that the Ra factor was set arbitrarily low, which effectively increased federal fuel economy standards and decreased demand for gasoline, harming their businesses.The case was reviewed by the United States Court of Appeals for the Fifth Circuit. The petitioners contended that the EPA's rule violated the Administrative Procedure Act (APA) by ignoring significant comments and data that flagged flaws in the determination of the Ra factor. They pointed out that the EPA's test program used too few and outdated vehicles, included data from a malfunctioning vehicle, and excluded data from a properly functioning one. Additionally, they argued that the EPA failed to consider alternative data sources, such as manufacturer certification data, which showed a higher Ra factor.The Fifth Circuit found that the EPA's rule was arbitrary and capricious. The court noted that the EPA did not adequately respond to significant comments that raised substantial issues with the test program's sample size, the representativeness of the vehicles tested, and the inclusion and exclusion of certain test data. The court also found that the EPA failed to justify its rejection of alternative data sources. As a result, the court held that the EPA did not demonstrate that its decision was the product of reasoned decision-making.The court granted the petition for review and vacated the portion of the EPA's rule that set and implemented the Ra factor of 0.81. The court concluded that there was no serious possibility that the EPA could substantiate its decision on remand, and thus, vacatur was the appropriate remedy. View "Texas Corn Producers v. EPA" on Justia Law

Dayana Garcia worked as a server at Gloria’s Restaurant for several months. After her employment ended, she filed a Fair Labor Standards Act (FLSA) suit against the restaurant's management entities and co-founder, alleging failure to pay minimum wage. The defendants initially participated in litigation, including answering the lawsuit, engaging in discovery, and mediating. They also filed a joint status report stating they had no intent to arbitrate. Five months after the lawsuit was filed, the defendants moved to compel arbitration.The United States District Court for the Northern District of Texas denied the motion to compel arbitration, finding that the defendants had waived their right to arbitrate by substantially invoking the judicial process. The defendants appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that the defendants had engaged in several litigative actions, including filing an answer without mentioning arbitration, participating in discovery, and mediating the dispute. The court also highlighted the defendants' explicit statement in the joint status report that they were not considering arbitration. The court concluded that these actions constituted a substantial invocation of the judicial process, thereby waiving the right to arbitrate. The Fifth Circuit affirmed the district court's denial of the motion to compel arbitration. View "Garcia v. Fuentes" on Justia Law

An inmate at Rayburn Correctional Center in Louisiana, Torriana Clark, filed a lawsuit under 42 U.S.C. § 1983 against prison officials, alleging that Lt. Lance Wallace used excessive force against him, violating his constitutional rights. Clark claimed that after feeling sick and seeking medical help, he was forcibly restrained and assaulted by Wallace, resulting in injuries. The prison officials' reports contradicted Clark's account, stating that Clark was combative and resisted orders, necessitating the use of force to restrain him.The United States District Court for the Eastern District of Louisiana granted partial summary judgment in favor of the defendants, ruling that Clark's § 1983 claim was barred by Heck v. Humphrey, which prevents prisoners from seeking damages under § 1983 if a judgment in their favor would imply the invalidity of their conviction or sentence. The district court also denied Clark's motion to amend his petition and remanded his state-law claims to state court.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Clark's § 1983 claim was indeed barred by Heck because success on his claim would require proof of facts inconsistent with his disciplinary convictions, which resulted in the loss of good-time credits. The court also agreed with the district court's denial of Clark's motion to amend his petition, concluding that any amendment would be futile as it would not change the Heck analysis. The appellate court's decision upheld the partial summary judgment and the denial of the motion to amend. View "Clark v. Dept of Public Safety" on Justia Law

Pamela Edwards, owner of Allure Salon in Starkville, Mississippi, was diagnosed with cancer in 2019 and passed away in 2022. After her death, her husband, Jimmy Edwards, sought payment from her life insurance policy with Guardian Life Insurance. Guardian denied the claim, stating the policy had been canceled because the number of insured employees at Allure dropped to one, triggering their right to cancel the policy. Jimmy Edwards was unaware of the policy until informed by the insurance agent, Debbie Jaudon, who also did not receive a cancellation notice from Guardian.Jimmy Edwards sued Guardian in the Northern District of Mississippi, bringing claims under Mississippi common law and arguing that ERISA entitled him to recover benefits. Guardian moved for partial summary judgment, asserting that ERISA governed the plan and preempted the common-law claims. The district court granted Guardian’s motion, and Jimmy Edwards appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that ERISA applied to the Allure policy, as the salon technicians were considered employees under federal common law. The court found that Guardian had waived its right to cancel the policy by continuing to accept premium payments for 26 months after the right to cancel vested. The court held that Guardian could not avoid its obligation to pay the claim after accepting premiums for such an extended period. Consequently, the Fifth Circuit reversed the district court's judgment and rendered judgment in favor of James Edwards. View "Edwards v. Guardian Life Insurance" on Justia Law

A group of plaintiffs, including individuals and community organizations, challenged the constitutionality of Louisiana’s Infrastructure Trespass Statute, arguing that amendments to the statute rendered it unconstitutionally vague and overbroad, violating the Due Process Clause and the First Amendment. The statute criminalizes unauthorized entry into critical infrastructure, including pipelines, and imposes significant penalties for violations.The United States District Court for the Western District of Louisiana granted summary judgment in favor of the defendants, including the Louisiana Attorney General, the District Attorney of the 16th Judicial District, and the Sheriff of St. Martin Parish. The district court dismissed claims against the Attorney General on sovereign immunity grounds and found that the Advocacy and Landowner Plaintiffs lacked standing. The court also dismissed the Arrested Plaintiffs' as-applied claims as moot due to the expiration of the statute of limitations for their alleged violations.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of claims against the Attorney General, agreeing that the Ex Parte Young exception to sovereign immunity did not apply. The court also upheld the dismissal of the Advocacy and Landowner Plaintiffs for lack of standing, finding that their alleged injuries were not traceable to or redressable by the remaining defendants. The court agreed that the Arrested Plaintiffs had standing for their facial challenges but affirmed the dismissal of their as-applied claims as moot.On the merits, the Fifth Circuit concluded that the Infrastructure Trespass Statute was neither impermissibly vague nor violative of the First Amendment. The court found that the statute provided sufficient notice of prohibited conduct and did not authorize arbitrary enforcement. The court also determined that the statute was not overbroad, as it served a substantial governmental interest in protecting critical infrastructure and did not substantially burden protected speech. The court affirmed the district court’s grant of summary judgment in favor of the defendants. View "White Hat v. Murrill" on Justia Law

Dr. Brian Carpenter was involved in a scheme to defraud TRICARE, the Department of Defense’s health insurance program. The scheme was orchestrated by Britt and Matt Hawrylak, who hired sub-reps to obtain medical information about TRICARE beneficiaries and identify doctors willing to write unnecessary prescriptions for compounded medications. These prescriptions were filled by Rxpress Pharmacy, which billed TRICARE at high rates. Carpenter, a podiatrist, was recruited by his co-defendant Jerry Hawrylak to write these prescriptions. Carpenter initially refused but later agreed to write prescriptions without receiving payment, claiming it was to help veterans. However, evidence showed that Carpenter's prescriptions were highly profitable for the Hawrylak brothers and Jerry, who made millions from the scheme.In September 2019, Carpenter and Jerry were indicted on six counts of healthcare fraud and one count of conspiracy to commit healthcare fraud. They were convicted on all counts in April 2023 by the United States District Court for the Northern District of Texas. Carpenter appealed, raising several issues, including the district court’s decision to excuse a juror mid-trial.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court abused its discretion by excusing a juror after the first day of trial without a legally relevant reason or factual basis. The juror was excused based on an email from her principal stating that her absence would cause hardship for her school, but there was no indication that the juror was unable to perform her duties. The appellate court held that this error was prejudicial and required vacating Carpenter’s convictions. The court remanded the case for a new trial. View "United States v. Carpenter" on Justia Law

Parents and students in Louisiana challenged a state statute requiring public schools to permanently display the Ten Commandments in every classroom. The statute, House Bill 71 (H.B. 71), mandated that the Ten Commandments be displayed prominently and legibly, with an optional inclusion of other historical documents. Plaintiffs argued that this statute violated the Establishment Clause and Free Exercise Clause of the First Amendment.The United States District Court for the Middle District of Louisiana found the statute facially unconstitutional and issued a preliminary injunction to prevent its enforcement. The court ruled that the statute's primary purpose was religious, not secular, and that it coerced students into religious observance, thus violating the Establishment Clause. Louisiana officials appealed the decision, arguing that the statute had a valid secular purpose and that the plaintiffs lacked standing.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the statute was unconstitutional under the Establishment Clause, relying on the precedent set by Stone v. Graham, which struck down a similar statute in Kentucky. The court found that the statute's requirement to display the Ten Commandments in every classroom, without integrating them into an educational curriculum, served no secular educational purpose and was inherently religious.The court also determined that the plaintiffs had standing to challenge the statute, as they would be directly affected by the displays. The court rejected Louisiana's arguments regarding ripeness, standing, and sovereign immunity. The preliminary injunction was upheld, preventing the enforcement of H.B. 71 and requiring Louisiana officials to notify all public schools of the court's ruling. View "Roake v. Brumley" on Justia Law