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

In this case, the families of Michael Jackson, Carl Wiley, Jr., and Rashad Henderson, who were killed during high-speed police chases in Houston, Texas, sued the City of Houston. They alleged that the Houston Police Department (HPD) has a policy of racial profiling that leads to more high-speed chases in predominantly black neighborhoods, resulting in the deaths of their loved ones. The plaintiffs brought several federal municipal liability claims, including violations of equal protection, Title VI, 42 U.S.C. § 1982, and substantive due process, as well as state tort claims.The United States District Court for the Southern District of Texas granted in part and denied in part Houston's motions to dismiss for lack of subject matter jurisdiction and for judgment on the pleadings. The court dismissed all claims except the equal protection claims and Jackson’s state law claims. Houston then filed an interlocutory appeal, raising issues regarding standing, failure to state federal claims, capacity to sue, and governmental immunity for Jackson’s state law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it lacked jurisdiction to review non-final district court orders except under 28 U.S.C. § 1292(b). The court found that it could only review whether the plaintiffs had standing to assert their equal protection claims. The court held that the plaintiffs lacked standing because their injuries did not stem from unequal treatment based on race. Consequently, the court reversed the district court’s order regarding standing for the equal protection claims and vacated the district court’s decision on governmental immunity for Jackson’s negligence claim, remanding the case for further proceedings. View "Jackson v. City of Houston" on Justia Law

In November 2023, Media Matters for America, a nonprofit organization, published articles critical of X Corp. and its CEO, Elon Musk, alleging that advertisements from popular brands were placed next to harmful content on the X platform. This led to significant losses for X as advertisers withdrew. X sued Media Matters and its employees in the federal district court for the Eastern District of Texas, alleging interference with contract, business disparagement, and interference with prospective economic advantage. Media Matters moved to dismiss the complaint for lack of personal jurisdiction, improper venue, and failure to state a claim, but the district court denied the motion. Media Matters then sought to certify the personal jurisdiction question for immediate appeal, which was also denied.The district court denied Media Matters' subsequent motion to transfer venue to the Northern District of California, citing untimeliness and a pattern of gamesmanship. Media Matters then filed a petition for writ of mandamus with the United States Court of Appeals for the Fifth Circuit, seeking a venue transfer based on 28 U.S.C. §§ 1404 and 1406.The United States Court of Appeals for the Fifth Circuit reviewed the petition and found that the district court had not properly considered the eight public- and private-interest factors required for a venue transfer analysis. The appellate court granted Media Matters' petition in part, vacated the district court's order denying the transfer, and remanded the case for a proper venue analysis. The court also held Media Matters' interlocutory appeal in abeyance pending the resolution of the remand. View "In Re: Media Matters for America" on Justia Law

A nonprofit organization, Students for Fair Admissions (SFFA), challenged the University of Texas at Austin (UT) for its admissions policies, alleging they violated the Equal Protection Clause and Title VI by considering race as a factor. After the Supreme Court's decision in Students for Fair Admissions, Inc., v. President & Fellows of Harvard College, UT revised its admissions policy to exclude race as a factor but allowed admissions officers access to applicants' racial data. SFFA claimed this access still constituted a violation and sought declaratory and injunctive relief.The United States District Court for the Western District of Texas dismissed all claims as moot, reasoning that UT's policy changes addressed the issues raised by SFFA. The district court concluded that the claims related to the old policy were moot and that the new policy did not violate the law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court agreed that claims related to UT's pre-Harvard policy were moot because the policy had been repealed and could not reasonably be expected to recur. However, the court found that claims related to UT's post-Harvard policy were not moot. The court noted that admissions officers' access to racial data could still potentially allow for racial discrimination, thus maintaining a live controversy.The Fifth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The court held that SFFA's claims regarding the revised admissions policy remained live and required further examination to determine if the policy was a subterfuge for continued race discrimination. View "Students for Fair Admissions v. University of Texas Austin" on Justia Law

William Navarre purchased a house that had been damaged by two hurricanes in 2020. The previous owners, Bal and Rita Sareen, had received insurance payments from AIG Property Casualty Company but had not assigned their post-loss insurance rights to Navarre at the time of the sale. Navarre filed a lawsuit against AIG, claiming he had been assigned these rights as of the purchase date. However, the formal assignment document was not executed until January 2023, well after the lawsuit was filed and after the prescriptive period for the claims had expired.The United States District Court for the Western District of Louisiana granted summary judgment in favor of AIG, concluding that Navarre lacked standing to file the lawsuit because the assignment of rights had not been executed at the time he filed the suit. The court also noted that the prescriptive period for the claims had expired by the time the assignment was executed.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed that the documents Navarre relied on (Addendum A and the Side Letter) did not constitute a present assignment of rights but rather contemplated a future assignment. Since the formal assignment was not executed until January 2023, Navarre did not have standing to sue when he filed the lawsuit in June 2022. Additionally, the court held that the prescriptive period for the claims had expired by the time the assignment was executed, and thus, Navarre could not retroactively cure the deficiency in his original petition. View "Navarre v. AIG Prop Cslty" on Justia Law

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

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

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

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

A group of staffing companies in Texas challenged a memorandum issued by the former General Counsel of the National Labor Relations Board (NLRB), Jennifer Abruzzo. The memorandum outlined a plan to urge the NLRB to reverse its holding in a previous case, Babcock, which allowed employers to compel employees to attend meetings where they were urged to reject union representation. The staffing companies argued that the memorandum violated their First Amendment rights by restricting their speech about unionization and sought an injunction and declaratory judgment against its enforcement.The United States District Court for the Eastern District of Texas dismissed the case for lack of jurisdiction, stating that the plaintiffs were challenging unreviewable prosecutorial decisions by the NLRB General Counsel, that the NLRA's scheme precluded jurisdiction, and that the plaintiffs lacked standing. The staffing companies appealed, arguing that the district court erred in its dismissal and that they had standing because the memorandum applied to them and was a final agency action reviewable under the Administrative Procedure Act (APA).The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the staffing companies lacked standing. The court noted that the plaintiffs had not provided evidence of a credible threat of enforcement of the memorandum causing them direct injury. The court also found that the plaintiffs did not demonstrate an intent to engage in conduct regulated by the memorandum, as there was no known unionization attempt at their businesses. The court concluded that the plaintiffs failed to establish a credible threat of enforcement or a substantial risk of future injury.The Fifth Circuit affirmed the district court's dismissal of the case for lack of standing. View "Burnett Specialists v. Cowen" on Justia Law

In March 2020, Jose Gonzalez visited a Walgreens store in Austin, Texas. An unidentified customer had clogged the toilet in the men's restroom and was given a plunger by a Walgreens employee to fix it. While the customer was attempting to unclog the toilet, Gonzalez entered the restroom and slipped on water that had accumulated on the floor. Gonzalez sued Walgreens for his injuries.The case was initially filed in Texas state court but was removed to the United States District Court for the Western District of Texas based on diversity jurisdiction. Gonzalez asserted a theory of vicarious liability and a claim for premises liability against Walgreens. The district court dismissed the vicarious liability theory and denied Walgreens's motion for summary judgment on the premises liability claim. After Gonzalez presented his case at trial, Walgreens moved for judgment as a matter of law (JMOL), which the district court granted, finding that Walgreens had no actual or constructive knowledge of the wet floor. Gonzalez's motion for a new trial was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's JMOL, holding that no reasonable jury could find that Walgreens had actual or constructive knowledge of the wet floor. The court found that Gonzalez failed to provide sufficient evidence that Walgreens knew or should have known about the hazardous condition. The court also affirmed the dismissal of Gonzalez's vicarious liability theory, stating that the allegations constituted a premises liability claim, not a basis for vicarious liability. The court concluded that Walgreens did not have a policy or practice that it knew routinely created an unreasonable risk of harm, distinguishing this case from others where such knowledge was established. View "Gonzalez v. Walgreen" on Justia Law