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

Defendant appealed his sentence and lifetime term of supervised release following a guilty plea to failing to register as a sex offender. The court found that the sentencing judge adequately explained her reasons for rejecting defendant's mitigating evidence and imposing an upward variance on the term of imprisonment. Therefore, defendant's sentence was procedurally reasonable. Likewise, the court held that the 27 months of imprisonment was substantively reasonable where the sentencing judge did not abuse her discretion by determining that defendant's willingness to cooperate did not mitigate his offense or criminal history, and in giving significant weight to defendant's criminal history and its characteristics. The court held, however, that the order regarding the lifetime term of supervised release must be vacated because the sentencing judge did not give reasons for her decision. View "United States v. Fraga" on Justia Law

Defendants were sentenced to death after being convicted of murdering a fellow prison inmate. Defendants appealed their sentences and convictions. The court held that the district court did not abuse its discretion in dismissing five prospective jurors who expressed reservations about their ability to impose capital punishment. The evidence overwhelmingly demonstrated premeditation and in view of this evidence, a jury could not rationally have found defendants guilty of second degree murder, while acquitting them of first degree murder. Accordingly, the district court did not abuse its discretion in denying defendants' request for a lesser-included-offense instruction. A rational juror could have concluded that defendants intended to inflict, and in fact did inflict, greater abuse than that necessary to cause the victim's death. A rational juror could have concluded that defendants posed a future threat to the safety of other inmates or prison staff based on, inter alia, defendants' pattern of violence and institutional misconduct, as well as defendants' attack on the victim and the penitentiary's correctional officers. Defendants have not demonstrated specific prejudice from the denial of their motion to sever. The court addressed defendants' remaining arguments and affirmed their convictions and capital sentences in all respects. View "United States v. Snarr, et al" on Justia Law

Defendant pleaded guilty, without the benefit of a plea agreement, of being unlawfully present in the United States after having been deported. On appeal, defendant challenged his sixteen-level sentencing enhancement under U.S.S.G. 2L1.2(b)-(1)(A)(ii). The court held that defendant's prior conviction of burglary of a habitation with intent to commit theft under Texas state law constituted a crime of violence because of its inherent potential for harm to persons. Accordingly, the court affirmed the sentence. View "United States v. Morales-Mota" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the Plan on his claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiff asserted that the Plan did not comply with procedures set out by ERISA by changing its basis for denial on administrative appeal and by not identifying the independent physician reviewer who recommended denial on administrative appeal. Because plaintiff did not specify the failure to identify the physician in his amended complaint, the court did not address this issue. The court agreed with plaintiff, however, that the Plan did not substantially comply with ERISA procedures by changing its basis for denying coverage on administrative appeal. The court concluded that remand to the Plan for a full and fair review was appropriate. View "Rossi v. Precision Drilling Oilfield Svcs. Corp. Emp. Benefits Plan" on Justia Law

Plaintiff appealed the district court's entry of an order declaring enforceable under general maritime law a liquidated damages provision (LD Provision) in a contract between defendant and plaintiff. The parties entered into a Vessel Sales Agreement (VSA), which included the LD Provision, that provided for a $250,000 payment for each violation of the non-competition clause. The court followed Farmers Exp. Co. v. M/V Georgis Prois in finding persuasive the district court's careful factual findings as to whether the LD Provision was a reasonable forecast of damages. The court held that looking at the contract at the time it was made, ex ante breach, the court could not bicker with the $250,000 per occurrence forecast. Plaintiff had not met its burden to prove that the LD Provision was a penalty. Therefore, the court concluded that the district court properly held that the LD Provision was enforceable and affirmed the judgment. View "International Marine, L.L.C., et al v. Delta Towing, L.L.C." on Justia Law

This case stemmed from the multi-district litigation involving the Deepwater Horizon drilling rig oil spill. Plaintiff appealed from the district court's dismissal of its action brought under the citizen-suit provisions of the Clean Water Act (CWA), 33 U.S.C. 1365(a)(1), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. 9659(a), and the Emergency Planning and Community Right-to-Know Act (EPCRA), 42 U.S.C. 11046(a). The court concluded, with one exception, that the district court did not err by dismissing plaintiff's claims as moot because the Macondo well had been capped and sealed; on the present state of the record, plaintiff had standing to assert its claim for relief based on defendants' alleged failure to comply with the reporting requirements of EPCRA; and the EPCRA claim was not moot. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "In Re: Deepwater Horizon" on Justia Law

Plaintiff sued her siblings based on diversity jurisdiction, alleging that the siblings, co-trustees of the Brunsting Family Living Trust, had breached their fiduciary duties to her, a beneficiary of the trust. At issue was the scope of the probate exception to federal subject matter jurisdiction in the wake of the Supreme Court's decision in Marshall v. Marshall. The court found no evidence that the trust was subject to the ongoing probate proceedings and concluded that the case fell outside the scope of the probate exception. Therefore, the district court erred in dismissing the case for lack of subject matter jurisdiction. View "Curtis v. Brunsting, et al" on Justia Law

Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Louisiana state court denied petitioner's application for a writ of habeas corpus. The federal district court subsequently granted habeas relief, determining that the state court's decision was based on an unreasonable determination of the facts. Petitioner claimed that he received ineffective assistance of counsel because his counsel did not investigate and interview alibi witnesses who would have testified that petitioner had not shot the victim. The court concluded that the state court's finding that petitioner's counsel interviewed alibi witnesses was not an unreasonable determination of the facts. Therefore, it was error to conclude as the district court did that there was no reasonable argument that counsel's performance was satisfactory. The court did not need to reach the issue of prejudice. Accordingly, the court affirmed the judgment. View "Kately v. Cain" on Justia Law

Plaintiff sued the school district alleging that the district's decision to hire a Caucasian woman in lieu of promoting him amounted to race discrimination in violation of Title VII. The district court granted summary judgment to the district and ordered plaintiff to pay attorneys' fees. The court found no competent evidence from which a reasonable juror could infer that the district's decision to hire the woman in lieu of promoting plaintiff was motivated by impermissible racial considerations. The court held, however, that the district court's fee award constituted an abuse of discretion where the court did not agree that plaintiff's claim was frivolous, unreasonable, or without foundation. View "Autry v. Fort Bend Independent Sch. Dist." on Justia Law

A third-party administrator of medical benefits plans, IMA, denied claims made on behalf of two patients who received treatment from the same medical provider, LifeCare. The court held that IMA incorrectly interpreted the plans because it categorized LifeCare as a skilled nursing facility (SNF) without finding that LifeCare "fully meets all of" the plans' seven SNF factors. IMA abused its discretion because categorizing LifeCare as an SNF without considering the seven-factors SNF test contradicted the plain language of the plans. The court found that the district court correctly held that LifeCare could maintain an action against IMA pursuant to 29 U.S.C. 1132(a)(1)(B) and that IMA was liable for exercising actual control over the claims process. The court further held that the district court did not abuse its discretion in awarding attorneys' fees. View "Lifecare Mgmt. Svcs., LLC v. Ins. Mgmt. Admins. Inc, et al" on Justia Law