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

A class of stock purchasers alleged that Anadarko Petroleum Corporation fraudulently misrepresented the potential value of its Shenandoah oil field project in the Gulf of Mexico, violating federal securities law. The plaintiffs claimed that a decline in Anadarko’s stock price resulted from the company's disclosure that the Shenandoah project was dry and that Anadarko was taking a significant write-off for the project. The plaintiffs invoked the Basic presumption, a legal principle that allows courts to presume an investor's reliance on any public material misrepresentations if certain requirements are met.The District Court for the Southern District of Texas certified the class, relying on new evidence presented by the plaintiffs in their reply brief. Anadarko argued that it was not given a fair opportunity to respond to this new evidence and appealed the decision.The United States Court of Appeals for the Fifth Circuit agreed with Anadarko, stating that the district court should have allowed a sur-reply when the plaintiffs presented new evidence in their reply brief. The court held that when a party raises new arguments or evidence for the first time in a reply, the district court must either give the other party an opportunity to respond or decline to rely on the new arguments and evidence. The court also agreed that the district court failed to perform a full Daubert analysis, a standard for admitting expert scientific testimony. The court vacated the class certification order and remanded the case for further proceedings. View "Georgia Firefighters' Pension Fund v. Anadarko Petroleum Corp." on Justia Law

Nicholas Queen, a former federal prisoner, filed a lawsuit against the United States under the Federal Tort Claims Act (FTCA), alleging that prison officials physically assaulted him in January 2019. The incident occurred when four correctional officers woke Queen up in his cell due to a supposed medical emergency. The parties dispute the events that followed, with the government claiming that Queen assaulted the officers, while Queen alleges that the officers physically attacked him without provocation. Following the incident, Queen complained of various physical pains, which he associated with the assault. However, prison medical officials dismissed his complaints, suggesting over-the-counter pain medication would suffice. After his release from prison, Queen was diagnosed with chronic back and right hip pain, which a medical doctor confirmed was severe enough to prevent him from working.The case was initially heard in the United States District Court for the Western District of Louisiana. The United States moved for the case to be dismissed at the summary judgment stage, arguing that Queen's injuries were de minimis and therefore insufficient to support an FTCA assault claim against a prison officer. The magistrate judge agreed with this argument and recommended dismissal. The district judge adopted this recommendation and dismissed Queen's case.Upon appeal to the United States Court of Appeals for the Fifth Circuit, the court found that the district court had erred in its decision. The appellate court noted that the de minimis injury test applied to constitutional claims does not apply to an injury alleged under Louisiana tort law, which does not impose a de minimis injury bar to tort claims. Therefore, the court reversed the district court's judgment and remanded the case for further proceedings. View "Queen v. United States" on Justia Law

The case revolves around the procedural interplay between two Mississippi statutes—the Mississippi Tort Claims Act (MTCA) and the Mississippi Whistleblower Protection Act (MWPA). Mark Johnson, the plaintiff, filed a retaliation complaint under the MWPA, alleging that he was fired from his position as general manager of the Clarksdale Public Utilities Authority (CPU) for reporting inefficiency and incompetence. Johnson later added claims for First Amendment retaliation and breach of contract.The district court held that the procedural requirements of the MTCA applied to Johnson’s MWPA claim, and because the court concluded he didn’t comply with them, it dismissed his claim. The district court also concluded that Johnson’s First Amendment retaliation and breach-of-contract claims were time-barred because the three-year statute of limitations for these claims ran after Johnson filed his first complaint but before he amended to add these claims—and neither claim relates back. Johnson appealed.The United States Court of Appeals for the Fifth Circuit was unable to make a reliable Erie guess as to whether the MTCA’s procedural requirements apply to MWPA claims because it lacked clear guidance from Mississippi courts on how the two statutes interrelate. Therefore, the court certified this question to the Supreme Court of Mississippi: When a plaintiff brings a claim against the government and its employees for tortious conduct under the MWPA, is that claim subject to the procedural requirements of the MTCA? View "Johnson v. Miller" on Justia Law

A group of Indian nationals, legally present in the United States on employment-based visas, filed a lawsuit against the Secretary of State and the Director of U.S. Citizenship and Immigration Services (USCIS). The plaintiffs were seeking permanent residency and challenged the defendants' approach to distributing immigrant visas. They argued that the defendants' policies of deferring adjudication of their applications until a visa number becomes available violated the statute governing adjustment of status for nonimmigrants. They sought injunctive and declaratory relief under the Administrative Procedure Act and the federal Declaratory Judgment Act.The plaintiffs had initially moved for a preliminary injunction in the United States District Court for the Eastern District of Texas, but their motion was denied. They appealed this decision to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit, however, found that it lacked subject-matter jurisdiction to hear the case. The court cited the Immigration and Nationality Act (INA), which strips federal courts of jurisdiction to address many challenges brought in the context of immigration proceedings. The court concluded that the INA's jurisdiction-stripping provisions precluded it from hearing the plaintiffs' challenge. The court vacated the district court's decision and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "Cheejati v. Blinken" on Justia Law

A group of business associations, including the Fort Worth Chamber of Commerce, filed a lawsuit in the Northern District of Texas against the Consumer Protection Financial Bureau (CFPB). The plaintiffs challenged a new Final Rule issued by the CFPB regarding credit card late fees and sought a preliminary injunction against the rule. The plaintiffs requested expedited briefing and review due to the imminent effect of the rule and the substantial compliance it required.The district court, instead of ruling on the motion for a preliminary injunction, considered whether venue was appropriate in the Northern District of Texas and invited the CFPB to file a motion to transfer the case. The CFPB complied, and the district court granted its motion, transferring the case to the United States District Court for the District of Columbia. The plaintiffs then petitioned for a writ of mandamus, arguing that the district court abused its discretion by transferring the case while their appeal was pending and, alternatively, lacked jurisdiction to transfer the case.The United States Court of Appeals for the Fifth Circuit agreed with the plaintiffs, stating that the district court acted without jurisdiction. The court explained that once a party properly appeals something a district court has done, in this case, the effective denial of a preliminary injunction, the district court has no jurisdiction to do anything that alters the case’s status. The court clarified that its decision was not about the correctness of the district court’s transfer order but rather about whether the court had jurisdiction to enter it. The court concluded that the district court did not have jurisdiction to transfer the case.The court granted the petition for mandamus, vacated the district court’s transfer order, and ordered the district court to reopen the case. The court also instructed the district court to notify the District of Columbia that its transfer was without jurisdiction and should be disregarded. View "In re: Chamber of Commerce" on Justia Law

The case revolves around Susan Miller, who sued Michaels Stores, Inc. for negligence after she slipped and fell in one of their stores in Slidell, Louisiana, during a rainstorm. Miller claimed that she had entered the store via a propped-open exit door, where no warning signs or mats were present, and subsequently slipped on a clear substance. She argued that a store employee had admitted to the presence of a warning sign and mat at the other door, indicating that the store was aware of the wet conditions but had failed to adequately warn customers.Earlier, the United States District Court for the Eastern District of Louisiana had granted summary judgment in favor of Michaels. The store had argued that Miller lacked evidence proving that they had notice of any hazards where she slipped. The district court ruled that none of the evidence showed that Michaels was aware of a hazard in the area where Miller fell, and hence granted summary judgement for Michaels.Upon review by the United States Court of Appeals for the Fifth Circuit, the court affirmed the district court’s decision. The court held that Miller's evidence was insufficient to show that Michaels had actual or constructive notice of the specific hazard that caused her fall. Furthermore, it ruled that the statements made by the Michaels employee were irrelevant to the issue of notice and were therefore inadmissible. Lastly, the court found no evidence that Michaels had spoiled any evidence, as alleged by Miller. Therefore, the court affirmed the summary judgment in favor of Michaels Stores. View "Miller v. Michaels Stores" on Justia Law

Highland Capital Management, L.P., a firm co-founded by James Dondero, filed for bankruptcy in 2019 due to litigation claims. As part of a settlement agreement, Dondero relinquished control of Highland to three independent directors, one of whom, James P. Seery, was appointed as Highland’s Chief Executive Officer, Chief Restructuring Officer, and Foreign Representative by the bankruptcy court. To protect Seery from vexatious litigation, the bankruptcy court issued an order that no entity could commence or pursue a claim against Seery relating to his role without the bankruptcy court's prior approval. Despite this, two entities founded by Dondero, the Charitable DAF Foundation and its affiliate CLO Holdco, filed a lawsuit against Highland in district court, alleging that Highland, through Seery, had withheld material information and engaged in self-dealing related to a settlement with one of its largest creditors, HarbourVest.The bankruptcy court held the appellants in civil contempt for violating its order and ordered them to pay $239,655 in compensatory damages. The district court affirmed the bankruptcy court's decision, concluding that the award was compensatory and therefore civil. The appellants appealed to the United States Court of Appeals for the Fifth Circuit, arguing that the sanction was punitive and thus exceeded the scope of the bankruptcy court’s civil contempt powers.The United States Court of Appeals for the Fifth Circuit vacated the district court's decision and remanded the case. The appellate court found that the bankruptcy court had abused its discretion by imposing a punitive sanction that exceeded its civil contempt powers. The court held that the sanction was not compensatory because it was not based on the damages Highland suffered due to the appellants' decision to file the motion in the wrong court. The court instructed the bankruptcy court to limit any sanction award to the damages Highland suffered because of this error. View "Charitable DAF Fund v. Highland Captl Mgmt" on Justia Law

This case involves a dispute between Sheet Pile, LLC and Plymouth Tube Company. The conflict arose from an exclusivity agreement, in which Plymouth agreed to manufacture certain products only for PilePro, Sheet Pile's predecessor. Approximately a decade later, Sheet Pile accused Plymouth of breaching this agreement by selling those products to other companies, and they sued for fraud and breach of contract. The district court granted summary judgment in favor of Plymouth.Sheet Pile then appealed. The Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the lower court's decision. For the breach-of-contract claim, the court concluded that the claim was time-barred under Texas law, which has a four-year statute of limitations for such claims. The court also held that the discovery rule, which could have deferred the accrual of the cause of action, did not apply.Regarding the fraud claim, the court concluded that Sheet Pile failed to demonstrate a genuine dispute of material fact that Plymouth's representations were false when made. The court noted that there was no evidence that Plymouth sold the exclusive products to third parties in 2014 or 2015, and that Plymouth had expressly warned PilePro that it might begin selling to third parties if PilePro didn't hold up its end of the agreement. Therefore, the court affirmed summary judgment for Plymouth. View "Sheet Pile v. Plymouth Tube" on Justia Law

In this case, the plaintiffs, Carl and Mary Ellen Schnell, filed an insurance claim with their home insurer, State Farm Lloyds, after a hailstorm damaged their home's roof. State Farm accepted coverage for some claims but denied others, including the claim that the City of Fort Worth required the Schnells to replace their entire roof, rather than just the damaged tiles. The Schnells sued, and the district court ruled in favor of State Farm. The Schnells appealed this decision.The United States Court of Appeals for the Fifth Circuit found that there were genuine issues of material fact that prevented the case from being resolved through summary judgment. The court found conflicting evidence regarding whether a building code administrator had flatly denied the Schnells' request for spot repairs or had conditioned his decision on the Schnells confirming that the old and new tiles on their roof did not interlock. The court also found a genuine dispute of fact about whether the Schnells' roof tiles were damaged by a covered risk like wind or hail, which would have triggered their insurance coverage.Thus, the court vacated the district court's summary judgment in favor of State Farm on the Schnells' breach of contract and Texas Prompt Payment of Claims Act claims. The court affirmed the remainder of the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Schnell v. State Farm Lloyds" on Justia Law

The case involves Michael Garrett, a prisoner in the Texas Department of Criminal Justice system for over thirty years, who contends that the prison's schedule allows him only three and a half hours of sleep per night, with a maximum of two and a half hours of continuous sleep. According to Garrett, this sleep deprivation constitutes a violation of the Eighth Amendment's ban on cruel and unusual punishment. He sued the Department after his complaints were ignored by prison officials.The United States District Court for the Southern District of Texas dismissed Garrett's claim, reasoning that he failed to demonstrate a direct causal relationship between his health issues and his sleep deprivation. The court also held that the prison officials' actions did not constitute deliberate indifference, as the schedule was based on legitimate penological purposes.Upon appeal, the United States Court of Appeals for the Fifth Circuit found that the district court had applied incorrect legal standards. The appellate court held that to establish a violation of the Eighth Amendment, a prisoner need only show a substantial risk of serious harm, not actual harm. Furthermore, the court clarified that the prison’s penological purpose has no bearing on whether an inmate has shown “deliberate indifference” for purposes of an Eighth Amendment claim. The case was vacated and remanded to the district court to apply the correct legal standards. View "Garrett v. Lumpkin" on Justia Law