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

The case involves a group of 214 plaintiffs who filed a lawsuit against Devon Energy Production Company, L.P. in a Texas state court, alleging that Devon had underpaid them over $100 million in oil-and-gas royalties. Devon, a citizen of Oklahoma, removed the case to federal court under the Class Action Fairness Act (CAFA). The plaintiffs sought to have the case remanded to the state court based on CAFA’s “local controversy” exception. The district court agreed and ordered the case to be remanded.On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the district court's interpretation of the statute. The appellate court found that not all plaintiffs had incurred their "principal injuries" (financial harm from Devon's alleged underpayment of royalties) in Texas, as required under the "local controversy" exception of CAFA.Accordingly, the appellate court vacated the district court's judgment remanding the case to state court and directed that the case be reinstated on the district court's docket. This ruling signifies that the case will proceed in federal court, not state court. The court's ruling also clarified an important aspect of the CAFA's "local controversy" exception, specifically that all plaintiffs must have incurred their "principal injuries" in the state where the action was originally filed for the exception to apply. View "Cheapside Minerals v. Devon Energy" on Justia Law

In this case, Glen Pace, a Mississippi resident, appealed the dismissal of his claims against multiple corporate defendants over personal injuries he suffered in a Texas airplane crash. The United States District Court for the Southern District of Mississippi dismissed the claims against the out-of-state defendants for lack of personal jurisdiction and held that the two Mississippi defendants were improperly joined, which allowed removal to federal court.Upon review, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s ruling. The appellate court agreed that Pace failed to state a claim against either in-state defendant, and thus, they were improperly joined. As for the out-of-state defendants, the court found that the district court lacked personal jurisdiction over them. The court reasoned that the aircraft crash, any equipment failure, and the injuries all occurred in Texas, and Pace's subsequent medical treatment and damages in Mississippi did not constitute an actual injury felt in the state for the purpose of establishing personal jurisdiction. The court held that Pace's injuries from the crash occurred in Texas and his subsequent medical treatment in Mississippi were "consequences stemming from the actual tort injury," which do not confer personal jurisdiction.The court also denied Pace's request for jurisdictional discovery, stating that Pace failed to present specific facts or reasonable particularity regarding jurisdictional facts. The court stressed that its decision should not be interpreted as implying a view on the merits of Pace’s claims. View "Pace v. Cirrus Design Corp" on Justia Law

In this case, Fieldwood Energy LLC, and its affiliates, who were previously among the largest oil and gas exploration and production companies operating in the Gulf of Mexico, filed for Chapter 11 bankruptcy in 2020 due to declining oil prices, the COVID–19 pandemic, and billions of dollars in decommissioning obligations. In the ensuing reorganization plan, some companies, referred to as the "Sureties", who had issued surety bonds to the debtors, were stripped of their subrogation rights. The Sureties appealed this loss in district court, which held their appeal to be statutorily and equitably moot. The Sureties appealed again to the United States Court of Appeals for the Fifth Circuit, contending that a recent Supreme Court decision altered the landscape around statutory mootness and that the district court treated Section 363(m) as jurisdictional. However, the appellate court affirmed the district court’s decision, concluding that the Supreme Court’s recent decision did not change the application of Section 363(m) in this case, the district court did not treat the statute as jurisdictional, and the Sureties’ failure to obtain a stay was fatal to their challenge of the bankruptcy sale. The court also determined that the provisions stripping the Sureties of their subrogation rights were integral to the sale of the Debtors’ assets, making the challenge on appeal statutorily moot. View "Swiss Re Corporate Solutions America Insurance Co. v. Fieldwood Energy III, L.L.C." on Justia Law

The case was brought before the United States Court of Appeals for the Fifth Circuit. The plaintiff, Jarius Brown, alleged that officers from the DeSoto Parish Sheriff's Office attacked him without provocation, leaving him to languish in a jail cell with a broken nose and eye socket. Almost two years later, Brown sued Javarrea Pouncy and two unidentified officers in the U.S. District Court for the Western District of Louisiana, seeking relief under 42 U.S.C. § 1983 for the alleged use of unreasonable force in violation of the Fourth and Fourteenth Amendments, as well as under Louisiana state law for battery. However, the district court dismissed Brown's Section 1983 claim as untimely under Louisiana's one-year statute of limitations for personal injury claims. Brown appealed this decision, arguing that the one-year period should not apply to police brutality claims brought under Section 1983 as it discriminates against such claims and practically frustrates litigants' ability to bring them.The Court of Appeals affirmed the district court's decision, holding that precedent required them to do so. The Court reasoned that while Brown's arguments that a one-year limitations period is too restrictive to accommodate the federal interests at stake in a civil rights action, the Supreme Court has yet to clarify how lower courts should evaluate practical frustration without undermining the solution it has already provided for the absence of a federal limitations period for Section 1983 claims. This was based on the principle that the length of the limitations period and related questions of tolling and application are governed by state law. The Court also noted that states have the freedom to modify their statutes to avoid being outliers in this regard. View "Brown v. Pouncy" on Justia Law

A Texas law, Senate Bill 1 (S.B. 1), related to voter registration and election integrity, was challenged by a group of plaintiffs (collectively referred to as LUPE) on the grounds that it chilled voter registration and was enacted with intent to discriminate against racial minorities. During the discovery phase of the lawsuit, LUPE sought documents and communications from the Harris County Republican Party (HCRP), which had been sent to or exchanged with the Texas Legislature and various members of the Texas executive branch regarding S.B. 1. The state defendants and non-party appellants (legislators) argued that some of these materials were protected by legislative privilege. The district court ruled that the legislative privilege did not apply.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court held that the legislative privilege was properly invoked and covered communications between the legislators and Alan Vera, the chair of the HCRP Ballot Security Committee, who had been involved in the legislative process relating to S.B. 1. The court further held that the legislative privilege did not yield under the circumstances of the case, as it did not meet the criteria for being an "extraordinary civil case" in which the privilege must yield. Therefore, the documents and communications sought by LUPE were protected by legislative privilege and not subject to discovery. View "La Union del Pueblo v. Bettencourt" on Justia Law

Thomas Rhone, a property owner in Texas City, Texas, had his apartments declared a nuisance by a Municipal Court of Record. Rhone disputed this decision in state court, but the City moved the case to federal district court. There, Rhone's claims were dismissed on summary judgment. Rhone appealed the district court's decision, challenging the standard of review and its conclusions regarding his constitutional claims. The United States Court of Appeals for the Fifth Circuit ordered a limited remand for the district court to conduct an evidentiary hearing on the role of the City Attorney in finalizing the Municipal Court’s order of abatement.Rhone's property, three apartment buildings, passed a city inspection in 2013 without any issues regarding a lack of a certificate of occupancy being raised. However, following an inspection in 2020, Texas City informed Rhone that his buildings were substandard and that he would need a certificate of occupancy to operate them. Rhone argued that city officials interfered with his efforts to remedy the violations claimed by the City and imposed conditions that made it impossible for him to preserve the value of his property by repairing the apartment buildings to bring them into compliance with the Texas City Code instead of demolishing the structures.After the city filed an administrative action in its Municipal Court of Record, the court ordered the demolition of the apartment buildings, finding them to be "dilapidated, substandard, unfit for human habitation, a hazard to the public health, safety, and welfare," and a nuisance. Rhone appealed this order in the 122nd Judicial District Court of Galveston County, but the City removed the action to the United States District Court for the Southern District of Texas in Galveston under federal-question jurisdiction. The federal district court ultimately granted partial summary judgment in favor of Texas City.The Court of Appeals held that any of Rhone's claims that would only interfere with the demolition of the buildings on his property were moot due to the demolition of the buildings. However, the court also held that the demolition did not eliminate a potential takings claim. The court ordered a limited remand for the district court to conduct an evidentiary hearing on the role of the City Attorney in finalizing the Municipal Court’s order of abatement. The court also held that Rhone has not shown that an initial inspection by a city fire marshal and an issuance of a citation that has consequences on his use of the property violate federal law. View "Rhone v. City of Texas City" on Justia Law

In this case, Larry Donnell Gibbs, a pro se plaintiff, filed a complaint under 42 U.S.C. § 1983 against five officers of the Texas Department of Criminal Justice. He alleged that two officers allowed him to bleed for 45 minutes after being stabbed by another inmate, and three other officers used excessive force against him in retaliation for filing a grievance about the incident. Gibbs attempted to proceed in forma pauperis, which would have allowed service to be made by a United States marshal, but the district court denied this on the basis that he had already paid the filing fee, had sufficient funds in his inmate trust account to serve the defendants, and had not provided the addresses of the defendants.The United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court found that the district court had abused its discretion by denying Gibbs's in forma pauperis status. It held that a person who is not a pauper at the commencement of a suit may become one during or prior to its prosecution. The court also found that the district court had arbitrarily determined that the funds in Gibbs's inmate trust account were sufficient for him to serve the defendants and that there's no requirement for an individual to be absolutely destitute to enjoy the benefit of in forma pauperis status. The court also held that a district court's determination of whether a party may proceed in forma pauperis must be based solely upon economic criteria and not on the lack of addresses for the defendants. The court concluded that the denial of Gibbs's in forma pauperis status had prejudiced his chances of effecting service. The case was remanded to the district court with instructions to permit Gibbs to proceed in forma pauperis. View "Gibbs v. Jackson" on Justia Law

In the case between Jennifer Harris and FedEx Corporate Services, Inc., Harris alleged race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964. The United States Court of Appeals for the Fifth Circuit found that Harris's § 1981 claims were time-barred under her employment contract, making them fail as a matter of law. However, the court found sufficient evidence to support the jury’s verdict for Harris on her Title VII retaliation claim. In view of Title VII’s $300,000 cap on damages and the evidence presented at trial, the court remitted Harris’s compensatory damages to $248,619.57 and concluded she was not entitled to punitive damages. FedEx was not entitled to a new trial because of the court’s evidentiary ruling. View "Harris v. FedEx Corporate Services" on Justia Law

In March 2019, the Waxahachie Police Department (WPD) SWAT Team mistakenly executed a search warrant on the wrong house, which was the home of Karen Jimerson, James Parks, and their two young children, instead of the intended target house. The error was due to Mike Lewis, the WPD SWAT Team Commander, incorrectly identifying the target house. The plaintiffs sued the officers under Section 1983 for violations of the Fourth Amendment and several state laws. The United States Court of Appeals for the Fifth Circuit reversed the district court's denial of summary judgment to Lewis on the issue of qualified immunity. The appellate court held that while Lewis's efforts to identify the correct residence were deficient, they did not violate clearly established law. The court found no genuine disputes of material fact, and it concluded that the disputed issue was one of law. The case was remanded for dismissal. View "Jimerson v. Lewis" on Justia Law

In a dispute between Conti 11 Container Schiffarts-GMBH & Co. KG M.S. and MSC Mediterranean Shipping Company S.A., the United States Court of Appeals for the Fifth Circuit found that the District Court for the Eastern District of Louisiana lacked personal jurisdiction over the case and reversed the district court's decision. The dispute arose from an incident where three chemical tanks exploded onboard a cargo vessel chartered by Conti to MSC, causing extensive damage and three deaths. After Conti won a $200 million award from a London arbitration panel, Conti sought to confirm the award in the Eastern District of Louisiana. MSC argued that the court lacked personal jurisdiction. The Fifth Circuit agreed with the district court’s assessment that when confirming an award under the New York Convention, a court should consider contacts related to the underlying dispute, not just those related to the arbitration itself. However, the Fifth Circuit disagreed with the district court's ruling that MSC waived its personal jurisdiction defense through its insurer’s issuance of a letter of understanding. The court also disagreed with the district court's finding that the loading of the tanks in New Orleans conferred specific personal jurisdiction over MSC, as this contact resulted from the actions of other parties not attributable to MSC. Therefore, the Fifth Circuit reversed the lower court's decision and remanded the case with instructions to dismiss it for lack of personal jurisdiction. View "Conti 11. Container Schiffarts-GMBH & Co. KG M.S. v. MSC Mediterranean Shipping Co. S.A." on Justia Law