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

William Maxwell, a federal prisoner, filed a 28 U.S.C. § 2241 petition for writ of habeas corpus, seeking transfer to a halfway house or home confinement under the First Step Act of 2018. He argued that the district court erred in determining that he failed to exhaust administrative remedies.The United States District Court for the Eastern District of Texas dismissed Maxwell's petition, concluding that he had not exhausted his administrative remedies. Maxwell appealed this decision, contending that the district court's determination was incorrect.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Maxwell's request for transfer to a halfway house or home confinement did not entitle him to accelerated release. According to the court's precedent in Melot v. Bergami, such relief should be sought through a civil rights suit rather than a habeas petition. Consequently, the court did not address whether Maxwell had exhausted his administrative remedies, as the proper vehicle for his claim was a civil rights suit, not a habeas petition. The court affirmed the district court's dismissal of Maxwell's petition. View "Maxwell v. Thomas" on Justia Law

The Bureau of Ocean Energy Management (BOEM) adopted a rule requiring current lessees of offshore drilling facilities in the Gulf of Mexico to obtain financial assurance bonds to cover potential future decommissioning liabilities. Several states and industry groups sued to vacate the rule, arguing it imposed undue financial burdens. The American Petroleum Institute (API), representing a broad range of oil and gas companies, sought to intervene in defense of the rule, claiming its members had unique interests in upholding it.The United States District Court for the Western District of Louisiana denied API's motion to intervene. The court found the motion procedurally defective because API did not attach a proposed answer to its motion, as required by local rules. Substantively, the court concluded that API failed to demonstrate that BOEM would inadequately represent its interests, a necessary showing for intervention as of right. The court also denied permissive intervention, suggesting that API could present its unique perspective through an amicus brief instead.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of API's motion to intervene. It held that API did not overcome the presumption that BOEM adequately represented its interests, as API failed to show any specific adversity of interest or actions by BOEM that were contrary to API's interests. The court also found no abuse of discretion in the district court's denial of permissive intervention, agreeing that API could effectively present its views as an amicus curiae. Thus, the district court's order denying intervention was affirmed. View "Louisiana v. Burgum" on Justia Law

Relators Tiffany Montcrief and others filed a False Claims Act suit against Peripheral Vascular Associates, P.A. (PVA), alleging that PVA billed Medicare for vascular ultrasound services that were not completed. The claims were categorized into "Testing Only" and "Double Billing" claims. The district court granted partial summary judgment to Relators, concluding that PVA submitted knowingly false claims. A jury found these claims material and awarded approximately $28.7 million in damages against PVA.The district court granted partial summary judgment to Relators on the issues of falsity and knowledge of falsity. The jury found that the claims were material and caused the Government to pay out money. The district court entered judgment against PVA, including statutory penalties and treble damages. PVA appealed, challenging the district court's grant of partial summary judgment and certain rulings during and after the trial.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's grant of partial summary judgment on the Testing Only claims but remanded for a new trial on damages. The court reversed the partial summary judgment ruling on the Double Billing claims, vacated the final judgment, and remanded for a new trial consistent with its opinion. The court concluded that the district court erred in interpreting the CPT–4 Manual and in concluding that the Manual required PVA to create separate, written reports for vascular ultrasounds before billing Medicare. The court also found that the district court abused its discretion in relying on Relators' post-trial expert declaration to calculate damages. View "Montcrief v. Peripheral Vascular" on Justia Law

Plaintiff-Appellant Perry Spriggs was struck by a U.S. Postal Service vehicle while riding his bicycle on Calliope Street in New Orleans on March 23, 2022. On March 23, 2023, Spriggs faxed his medical records and a signed Standard Form 95 (SF-95) to the Postal Service, addressed to Tara D. Lennix, a Louisiana District Tort Claims/Collections Specialist, at the correct fax number. Spriggs received a fax confirmation stating successful transmission. On March 22, 2024, Spriggs filed a lawsuit against the United States for personal injury and property damage from the accident.The United States District Court for the Eastern District of Louisiana dismissed Spriggs’s claims with prejudice, granting the United States' Federal Rule of Civil Procedure 12(b)(1) motion to dismiss for lack of subject matter jurisdiction. The court found no affirmative evidence of receipt of the SF-95 by the Postal Service, relying on declarations from Postal Service employees stating they did not receive the fax. The court also dismissed the claims under Rule 12(b)(6) due to the expiration of the two-year statute of limitations for presentment to the agency.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in disregarding the fax confirmation sheet as probative evidence of presentment under the Federal Tort Claims Act (FTCA). The Fifth Circuit held that a fax confirmation sheet indicating successful transmission to the correct recipient is probative evidence that the FTCA’s presentment requirement has been satisfied. The court vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Spriggs v. United States" on Justia Law

Highland Capital Management, L.P., a Dallas-based investment firm, filed for Chapter 11 bankruptcy in 2019 due to numerous unpaid judgments and liabilities. During the bankruptcy proceedings, James Dondero, a co-founder, stepped down as a director and officer but continued as an unpaid portfolio manager. The unsecured creditors' committee and independent directors opposed Dondero's reorganization plans, leading to his resignation in October 2020. The bankruptcy court held Dondero in civil contempt and sanctioned him for obstructing the proceedings. The proposed reorganization plan included provisions to shield Highland Capital and associated entities from liability, including an Exculpation Provision and an Injunction Provision with a Gatekeeper Clause.The bankruptcy court confirmed the plan, but on direct appeal, the United States Court of Appeals for the Fifth Circuit reversed the plan in part, striking certain non-debtors from the Exculpation Provision. The investment fund parties requested clarification on whether the same entities should be removed from the Gatekeeper Clause. The bankruptcy court conformed the plan by narrowing the definition of "Exculpated Parties" but did not change the definition of "Protected Parties" in the Gatekeeper Clause, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the bankruptcy court failed to implement its instructions properly. The court held that the definition of "Protected Parties" in the Gatekeeper Clause must be narrowed to include only the Debtor, the Independent Directors for conduct within their duties, the Committee, and the members of the Committee in their official capacities. The court reversed the bankruptcy court's decision in part and remanded the case for the plan to be revised accordingly. View "Highland Capital Fund Advisors v. Highland Capital Management" on Justia Law

Tracy Langiano alleged that he was shot and injured by Officer Landon Rollins in violation of the Fourth Amendment and that the City of Fort Worth’s policies contributed to this violation. Langiano was accused of sexually abusing his step-granddaughters and left his home after writing a suicide note. He checked into a motel with a loaded handgun, intending to kill himself. His son informed the police about the suicide note and the handgun. Police located Langiano at the motel, and Officer Rollins, without knocking, entered the room. Rollins claimed Langiano pointed a gun at him, prompting Rollins to shoot Langiano multiple times. Langiano disputed pointing the gun at Rollins but admitted holding it.The United States District Court for the Northern District of Texas denied Langiano’s motion to stay the civil suit while criminal charges were pending. The court granted summary judgment in favor of Officer Rollins and the City of Fort Worth, dismissing Langiano’s civil suit. Langiano appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the stay, as Langiano did not demonstrate substantial and irreparable prejudice. The court also affirmed the summary judgment in favor of Officer Rollins, finding that Rollins’ use of force was reasonable given the circumstances and that Langiano’s Fourth Amendment rights were not violated. Additionally, the court held that the warrantless entry into the motel room was justified due to the exigent circumstances of Langiano being armed and suicidal. The court also affirmed the summary judgment in favor of the City, as there was no constitutional violation to support a Monell claim. The district court’s judgment was affirmed. View "Langiano v. City of Fort Worth" on Justia Law

Kafi, Inc. ("Kafi") owns a residential property in League City, Texas, which it purchased from Joe and Kelly Richardson in September 2020. The Richardsons had financed the property with a loan from Sand Canyon Corporation in 2006, secured by an Adjustable Rate Note and a Deed of Trust. Sand Canyon transferred its interest in the loan to Wells Fargo Bank, N.A. ("Wells Fargo") in October 2006. Kafi challenged Wells Fargo's right to foreclose on the property, claiming the assignment of the Deed of Trust was forged. Kafi also sought equitable redemption, arguing it should be allowed to pay off any valid liens before foreclosure.The case was initially filed in Texas state court and then removed to the United States District Court for the Southern District of Texas. The district court dismissed Kafi's claims against Sand Canyon and Nationwide Title Clearing, Inc., and dismissed Kafi's standalone forgery claim and claim for exemplary damages. The court allowed Kafi's claims for declaratory relief, quiet title, and equitable redemption to proceed. Wells Fargo and PHH Mortgage Corporation filed a motion for summary judgment, which the district court granted, dismissing Kafi's remaining claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that Wells Fargo, as the holder of the Note, had standing to foreclose on the property under Texas law, regardless of the alleged forgery in the assignment of the Deed of Trust. The court also upheld the dismissal of Kafi's equitable redemption claim, noting that Kafi failed to provide sufficient evidence that it was ready, willing, and able to pay the redemption amount. The court emphasized that Kafi's declaration, which stated it was ready, able, or willing to redeem the property, was insufficient to meet the conjunctive requirement of being ready, willing, and able. Thus, the Fifth Circuit affirmed the district court's summary judgment in favor of Wells Fargo. View "Kafi, Inc. v. Wells Fargo Bank" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law

Charles and Yvette Whittier sued Ocwen Loan Servicing, Deutsche Bank National Trust Company, Merscorp, and Mortgage Electronic Registration System to prevent the foreclosure of their home mortgage loan. The parties reached a settlement and notified the district court, which issued an interim order of dismissal pending final documentation. The parties then filed a Joint Stipulation to Dismiss Action under Rule 41(a)(1)(A)(ii) and a proposed Order of Dismissal With Prejudice, which stated that the court would retain jurisdiction to enforce the settlement agreement. However, the court's dismissal order did not explicitly retain jurisdiction or incorporate the settlement terms.The Whittiers later filed a motion to enforce the settlement agreement and sought attorneys' fees. The defendants argued that the court lacked ancillary jurisdiction to enforce the agreement. A magistrate judge recommended enjoining foreclosure proceedings, and the district judge adopted this recommendation, issuing an injunction in April 2020. Over two years later, PHH and Deutsche Bank moved to reopen the case and dissolve the injunction, claiming the Whittiers were in default. A different magistrate judge found that the court lacked ancillary jurisdiction to enforce the settlement and recommended dissolving the injunction. The district judge agreed, dissolved the injunction, and dismissed the suit with prejudice in May 2024, explicitly declining jurisdiction over the settlement agreement.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the district court lacked ancillary jurisdiction to enforce the settlement agreement because the dismissal order did not expressly retain jurisdiction or incorporate the settlement terms. The court affirmed the district court's decision to dissolve the injunction and dismiss the case with prejudice. View "Whittier v. Ocwen Loan Servicing" on Justia Law

In 2016, the DOJ sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act, alleging unconstitutional conditions in the county's detention facilities. A consent decree was established to address these issues, but disputes over compliance led to ongoing litigation. The DOJ claimed the county failed to comply, citing worsening conditions, while the county sought to terminate the decree. The district court found partial compliance, held the county in contempt, and issued a new injunction focusing on the Raymond Detention Center (RDC). As a sanction, the court appointed a receiver to oversee compliance.The district court's decision was based on findings of ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, and poor conditions. The court noted that despite some improvements, many issues persisted, such as severe understaffing and inadequate supervision, contributing to violence and unsafe conditions. The court also found deficiencies in use-of-force training, incident reporting, and investigations, which exacerbated the problems.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to retain the new injunction, finding that ongoing constitutional violations justified continued prospective relief. However, the appeals court found the new injunction overly broad in some respects and held that the district court did not abuse its discretion in appointing a receiver. The court also noted that the district court failed to make sufficient need-narrowness-intrusiveness findings for each of the receiver's duties as required under the Prison Litigation Reform Act. Consequently, the appeals court affirmed the district court's decision in part, reversed in part, and remanded for further proceedings to address these issues. View "United States v. Hinds County Board of Supervisors" on Justia Law