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

Plaintiffs filed suit against their employer, CTS, alleging that they worked more than forty hours a week and that CTS wrongfully denied them overtime pay in violation of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. The court affirmed the district court's holding that the Motor Carrier Act (MCA), 49 U.S.C. 31502, exempted certain CTS employees from the overtime-pay requirements of the FLSA based, in part, on the percentage of safety-affecting interstate activities these employees engaged in company-wide. The court held that the company-wide analysis was appropriate in this case because this court's precedent effectively forecloses an employee-by-employee analysis, and the facts of this case, and arguments advanced by the parties, did not support a district-by-district analysis. View "Allen, et al. v. Coil Tubing Services, L.L.C., et al." on Justia Law

Plaintiffs filed suit seeking statutory damages under the Truth in Lending Act (TILA), 15 U.S.C. 1640(a)(2)(A), claiming that Buy Direct (dba Direct Buy) failed to provide the dates that payments would be due on an installment contract for membership in Direct Buy's wholesale membership club. The court reversed the district court's grant of summary judgment to Direct Buy, concluding that Direct Buy failed to make the required disclosures to plaintiffs, who therefore were entitled to damages. View "Lea, et al. v. Buy Direct, L.L.C." on Justia Law

Defendant appealed his sentence for conspiracy to bring illegal aliens into the United States, bringing illegal aliens into the United States, and being unlawfully present in the United States following a prior deportation. The court vacated and remanded the case for resentencing because the court concluded that the district court erred in its application of the grouping guidelines when grouping defendant's counts of conviction. View "United States v. Garcia-Figueroa" on Justia Law

Defendant appealed his sentence for being a felon unlawfully in possession of a firearm. The district court concluded that defendant's prior federal conviction for escaping from the custody of the BOP by leaving a halfway house was a "crime of violence" within the meaning of U.S.S.G. 4B1.2(a). The court concluded that it was bound by its en banc ruling in United States v. Charles, which permitted consideration of the conduct alleged in the indictment. The indictment underlying defendant's conviction alleged that he knowingly escaped from the custody of the BOP, by absconding from a halfway house in which he was lawfully confined. Thus, the conduct charged on the face of the indictment was that defendant absconded from a halfway house. Absconding from a halfway house does not categorically present a serious potential risk of physical injury to another. Accordingly, the court vacated the sentence and remanded for further proceedings. View "United States v. Jones" on Justia Law

Plaintiffs appealed the district court's grant of summary judgment in favor of LINA upholding LINA's denial of life insurance benefits to plaintiffs, beneficiaries of two policies. The court concluded that LINA properly denied coverage to plaintiffs as the insured's death fell within the policies' explicit exclusion for accidents involving the operation of a vehicle while intoxicated. The court held that the plain meaning of the word "vehicle" as used in the policies was unambiguous and broad enough to encompass a boat. Accordingly, the court affirmed the district court's grant of summary judgment to LINA. The court also affirmed the modification of the discovery order. View "Green, et al. v. Life Ins Co. of N. America" on Justia Law

Defendant appealed her conviction for possessing with the intent to distribute more than five kilograms of cocaine. The court affirmed the district court's judgment because the evidence at issue did not amount to an improper drug courier profile and because the court recognized that defendant's knowledge argument was foreclosed by the court's precedent. View "United States v. Medeles-Cab" on Justia Law

Whitehouse appealed a second time from a ruling of the Tax Court disallowing a significant portion of a tax deduction claimed for a historic conservation easement. The easement burdened the Maison Blanche building in New Orleans with a number of restrictions and affirmative obligations, all revolving around maintaining the appearance of the ornate facade. Whitehouse claimed a charitable contribution deduction for the easement. The Commissioner allowed a deduction for less than the amount Whitehouse claimed and further assessed a gross undervaluation penalty. The court affirmed the tax court's second valuation; vacated the tax court's enforcement of the gross undervaluation of the penalty because the tax court clearly erred in applying it; and remanded for entry of judgment. View "Whitehouse Hotel Ltd. Prtnshp., et al. v. CIR" on Justia Law

GE Plaintiffs filed suit against Worthington under the Texas Uniform Fraudulent Transfer Act (TUFTA), Tex. Bus. & Comm. Code 24.009(a), seeking to void transfers that Worthington received from the GE Plaintiffs' predecessor-in-interest, allegedly with notice of the transfers' fraudulent nature. The jury found in favor of the GE Plaintiffs and the district court entered judgment for the amount of the transfers. The court concluded that the factual commonality in this case did not suffice to count the contractual dispute settlement against TUFTA's limit on recovery for a single avoidance "claim," or to render Citibank a joint tortfeasor for one-satisfaction rule purposes. Accordingly, the district court did not err in denying Worthington a settlement credit for the settlement proceeds that the GE Plaintiffs received from Citibank. The court rejected Worthington's argument that the district court erred as a matter of law in interpreting TUFTA's good faith defense as an objective standard. Accordingly, the court affirmed the judgment of the district court. View "GE Capital Commercial, Inc., et al. v. Wright & Wright, Inc." on Justia Law

This appeal arose from an insurance coverage dispute concerning an industrial accident that occurred on a decommissioned platform in the Outer Continental Shelf. The key issue on appeal was whether the district court entirely disposed of any one claim against Continental. The court need not conclusively determine whether Tetra and Maritech have asserted one claim or two against Continental because, even if the court were to construe their request for a declaration on Continental's indemnity obligations as a single claim, it was clear that the district court did not fully dispose of that one claim. Accordingly, the court dismissed for want of jurisdiction. View "Tetra Technologies, Inc., et al. v. Vertex Services, L.L.C." on Justia Law

Plaintiff and her husband filed suit against Wal-Mart after she fell while entering through an automatic sliding door at a Wal-Mart store and sustained injuries. At issue on appeal was whether the district court erred when it granted summary judgment to Wal-Mart based on its conclusion that the defect in the door threshold was not unreasonably dangerous as a matter of law. The court concluded that the district court erred in extending Mississippi's so-called "categorical exemption" to defective thresholds; the fact that the alleged defective condition changed suddenly and without warning was sufficient for a reasonable jury to conclude that it created an unreasonable or unusually dangerous condition; and plaintiffs point to evidence in the record indicating that Wal-Mart may not inspect the doors to ensure they are functioning correctly and that despite an internal policy calling for daily inspections, the assistant manager of the store had no knowledge of that policy. Accordingly, the court reversed the district court's grant of summary judgment to Wal-Mart and the dismissal of both plaintiffs' claims, remanding for further proceedings. View "Cox, et al. v. Wal-Mart Stores, Inc." on Justia Law