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

Plaintiffs, two unmarried individuals who adopted a Louisiana-born infant in New York state, sued Louisiana's Registrar of Vital Records and Statistics ("Registrar") when she refused to reissue the infant's birth certificate with plaintiffs' names supplanting the biological parents' names. At issue was whether plaintiffs' had standing to sue on behalf of themselves and the infant, whether federal courts had jurisdiction to decide plaintiffs' claims under 42 U.S.C. 1983 for violation of the full faith and credit clause, and whether plaintiffs had a claim under the equal protection clause. The court held that plaintiffs had alleged actionable claims and had standing to sue on behalf of themselves and their infant. The court also held that the Registrar did not violate the full faith and credit clause by determining how to apply Louisiana's laws to maintain its vital statistics records where there was no basis on which to conclude that failure to issue a revised birth certificate denied "recognition" of the New York adoption decree. The court further held that denying the birth certificate to children of unmarried couples did not violate the equal protection clause where Louisiana had a legitimate interest in encouraging a stable and nurturing environment for the education and socialization of its adopted children and where Louisiana may rationally conclude that parenthood focused on a married couple or single individual, not on the freely severable relationship of partners, furthered the interests of adopted children.

Plaintiff, Barden Mississippi Gaming LLC ("Barden"), brought a declaratory judgment action against defendants, Great Northern Insurance Company ("Great Northern") and Top Line Seating, Inc. ("Top Line"), where in an earlier appeal brought by Barden, the court concluded that under the terms of an insurance policy between the parties, Great Northern had a duty to defend Barden in a tort suit brought by an individual who had been injured on the premises of Barden's casino through the use of a stool sold by Top Line. At issue was whether Barden was entitled to indemnification from Great Northern and Top Line for the underlying judgment in the prior case. Also at issue was whether Barden was entitled to recovery of attorneys' fees and costs incurred in pursuing the present declaratory judgment action. The court held that under the insurance policy between the parties, Great Northern and Top Line were not obligated to indemnify Barden for the judgment in the prior case where the jury in that case determined that Top Line was not 100% negligent. The court also held that Barden was not entitled to recover attorneys' fees and costs where Barden failed to establish any possible basis for its claim.

Defendant, former Enron Corporation CEO, appealed a conviction of conspiracy, securities fraud, making false representations to auditors, and insider trading. At issue was whether the error committed by the district court in submitting the honest-services theory to the jury was harmless as to any of defendant's convictions. The court held that the error was harmless and thus concluded beyond a reasonable doubt that the verdict would have been the same absent the alternative-theory errors where the jury was presented with overwhelming evidence that defendant conspired to commit securities fraud.

Plaintiffs, purchasers of condominium units at a planned development on the Mississippi Gulf Coast, demanded rescission of their sales contracts on the basis of violations of the Interstate Land Sales Full Disclosure Act ("ILSA"). At issue was whether plaintiffs' condominium units were exempt from the disclosure requirements of ILSA and therefore, defendant would not be liable for failing to provide the required property report. The court held that plaintiffs' condominium units were not entitled to an ILSA exemption and therefore, defendant violated ILSA when it did not provide the required disclosures.

Plaintiffs, purchasers of condominium units at a planned development on the Mississippi Gulf Coast, demanded rescission of their sales contracts on the basis of violations of the Interstate Land Sales Full Disclosure Act ("ILSA"). At issue was whether plaintiffs' condominium units were exempt from the disclosure requirements of ILSA and therefore, defendant would not be liable for failing to provide the required property report. The court held that plaintiffs' condominium units were not entitled to an ILSA exemption and therefore, defendant violated ILSA when it did not provide the required disclosures.

Plaintiffs, purchasers of condominium units at a planned development on the Mississippi Gulf Coast, demanded rescission of their sales contracts on the basis of violations of the Interstate Land Sales Full Disclosure Act ("ILSA"). At issue was whether plaintiffs' condominium units were exempt from the disclosure requirements of ILSA and therefore, defendant would not be liable for failing to provide the required property report. The court held that plaintiffs' condominium units were not entitled to an ILSA exemption and therefore, defendant violated ILSA when it did not provide the required disclosures.

Plaintiffs, purchasers of condominium units at a planned development on the Mississippi Gulf Coast, demanded rescission of their sales contracts on the basis of violations of the Interstate Land Sales Full Disclosure Act ("ILSA"). At issue was whether plaintiffs' condominium units were exempt from the disclosure requirements of ILSA and therefore, defendant would not be liable for failing to provide the required property report. The court held that plaintiffs' condominium units were not entitled to an ILSA exemption and therefore, defendant violated ILSA when it did not provide the required disclosures.

Defendant appealed his 180 month prison sentence after pleading guilty to one count of possession with intent to distribute cocaine base and one count of being a felon in possession of a firearm. At issue was whether the district court abused its discretion in sentencing defendant to 180 months incarceration. The court held that the district court adhered to correct sentencing procedure and imposed a sentence that was substantively reasonable in light of defendant's past involvement with a drug-trafficking organization.

Petitioner appealed the Tax Court's ruling that her settlement proceeds, received as a result of a discrimination suit against her employer, was taxable income in 2006. At issue was whether the $50,000 lump sum payment to "resolve and settle all differences, disputes, and controversies between the parties" in an action concerning various employment-related claims was excludable from a taxpayer's income under Internal Revenue Code 104(a)(2). The court held that the Tax Court did not err in concluding that the settlement proceeds were income where petitioner failed to demonstrate that her employer intended to allocate any specific portion or the entire amount of the settlement for her personal physical injury or physical illness.

Plaintiff sued defendant alleging that defendant misappropriated plaintiff's trade secrets related to a meat-packing method, which used a zero parts-per-million oxygen-storage atmosphere, after plaintiff visited defendant's plant to demonstrate its meat-packing method. At issue was whether the district court considered plaintiff's affidavit on reconsideration and whether defendant's motion for summary judgment was properly granted. The court held that the district court properly considered plaintiff's objected-to evidence when ruling on its motion for consideration; that the district court erred by entering summary judgment in favor of defendant when it incorrectly defined plaintiff's trade secrets and failed to consider that a unique combination of elements already publicly disclosed or generally known were protectable as trade secrets under Texas law; and that the district court properly denied plaintiff's partial summary judgment claim on the existence of a fiduciary duty and did not err when it failed to sua sponte enter judgment in plaintiff's favor.