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

This is an appeal from the denial of a preliminary injunction. While this appeal was pending, the district court subsequently dismissed Plaintiffs’ claims. The Fifth Circuit dismissed the appeal as moot. The court explained that there is no need for a preliminary injunction to preserve the status quo during the pendency of trial court proceedings that are now over. View "Koppula v. Jaddou" on Justia Law

Plaintiff sued the Austin Independent School District (“AISD”) on behalf of her minor son, A.H., alleging that AISD violated Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (“ADA”), and 42 U.S.C. Section 1983by employing an individual assigned to help A.H. accommodate his disabilities, but who instead verbally harassed him and threw a trash can at him, hitting him and causing injury. After the incident, the parties settled all of A.H.’s Individuals with Disabilities Education Act (“IDEA”) claims outside of court but agreed that Plaintiff still had the right to file a separate action containing A.H.’s claims arising under Section 504, the ADA, and Section 1983. Heston then brought these claims in a suit filed in 2018. The district court dismissed the suit without prejudice for Plaintiff’s failure to exhaust the Individuals with Disabilities Education Act’s (“IDEA”) administrative remedies.   The Fifth Circuit vacated the district court’s judgment and remanded it to the district court for further consideration in light of Luna Perez v. Sturgis Pub. Schs., 143 S. Ct. 859 (2023). Since Plaintiff appealed and the Parties’ briefed the case, the Supreme Court decided Luna Perez, concluding that the IDEA does not require administrative exhaustion “where a plaintiff brings a suit under another federal law for compensatory damages.” This constitutes a “modification in controlling legal principles . . . rendering a previous determination inconsistent with the prevailing doctrine.” View "Heston v. Austin Indep" on Justia Law

The attorney appointed to represent Defendant moved for leave to withdraw and has filed a brief in accordance with Anders v. California, 386 U.S. 738 (1967), and United States v. Flores, 632 F.3d 229 (5th Cir. 2011). Defendant did not file a response.The Fifth Circuit granted the motion to withdraw. The court concurred with counsel’s assessment that the appeal presents no nonfrivolous issue for appellate review. The court wrote that consistent with Crawley, it holds that Defendant’s restitution order does not present a nonfrivolous issue for appeal because he is liable for the same restitution amount regardless of the ultimate recipients. View "USA v. Fults" on Justia Law

This dispute began in 2016 when Defendants sued a motorist in state court for damages stemming from an automobile accident. The motorist fled the scene of the accident, was criminally charged for failing to provide his name, address, and insurance information, and pleaded nolo contendere to a criminal misdemeanor. The motorist was insured by Allstate Fire & Casualty Insurance Company (“Allstate”). Allstate paid Defendants claims for property damages, but Defendants rejected Allstate’s offers to resolve their physical injury claims, demanding the policy limit of $50,000. The district court determined that it had subject matter jurisdiction over the lawsuit, denying Defendants’ motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1). It subsequently granted summary judgment in favor of Allstate, finding that the motorist’s failure to cooperate in the underlying suit prejudiced Allstate and barred any legal obligation to pay Defendants the judgment amount of $163,822.   The Fifth Circuit affirmed the district court’s determination that it had subject matter jurisdiction. The court held that where the claim under the policy exceeds the value of the policy limit, courts considering declaratory judgments should ask whether there is a legal possibility that the insurer could be subject to liability in excess of the policy limit. The party seeking diversity jurisdiction should establish this possibility by a preponderance of the evidence. View "Allstate Fire and Casualty v. Allison Love" on Justia Law

Plaintiff brought a Fair Labor Standards Act (“FLSA”) suit against Rehab Synergies alleging violations of the federal overtime law. The district court, over Rehab Synergies’ objection, allowed the case to proceed as a collective action and a jury found Rehab Synergies liable. On appeal, Rehab Synergies contends that the district court abused its discretion by allowing the case to proceed as a collective action.   The Fifth Circuit affirmed. The court concluded that the district court applied the correct legal standards and that its factual findings were not clearly erroneous. The court explained that Plaintiffs’ adverse-inference argument does not suggest a “disparity” as a result of the case proceeding as a collective action; rather, the record shows that any “disparity” had other causes. Because the Plaintiffs were similarly situated, it would have been inconsistent with the FLSA to require 22 separate trials absent countervailing due process concerns that are simply not present here. View "Loy v. Rehab Synergies" on Justia Law

This litigation challenges the bail practices of one Louisiana parish. The claim is that money bail is required for pretrial detainees without consideration of alternatives, violating the rights of indigents to substantive due process and equal protection. The district court denied all relief.   The Fifth Circuit held that abstention is mandated and remanded in order that the district court may dismiss the suit. The court explained that Texas courts are neither unable nor unwilling to reconsider bail determinations under the proper circumstances, thus providing state court detainees the chance to raise federal claims without the need to come to federal court. Here, Plaintiffs have failed to show that Louisiana is unable or unwilling to reconsider bail determinations. How quickly those can be reconsidered is irrelevant because “arguments about delay and timeliness pertain not to the adequacy of a state proceeding, but rather to ‘conventional claims of bad faith.’” View "Little v. Doguet" on Justia Law

Two Texas employers: Braidwood Management, Inc. (“Braidwood”) and Bear Creek Bible Church (“Bear Creek”), filed suit, as per their closely held religious beliefs, asserting that Title VII, as interpreted in the EEOC’s guidance and Bostock, prevents them from operating their places of employment in a way compatible with their Christian beliefs. Plaintiffs have implicitly asserted that they will not alter or discontinue their employment practices. all parties admitted in district court that numerous policies promulgated by plaintiffs (such as those about dress codes and segregating bathroom usage by solely biological sex) already clearly violate EEOC guidance. Both plaintiffs also contend that they are focused on individuals’ behavior, not their asserted identity.   The Fifth Circuit affirmed the district court’s conclusion that plaintiffs’ claims are justiciable; reversed the class certifications; affirmed the judgment against Bear Creek; affirmed the ruling that Braidwood is statutorily entitled to a Title VII exemption; vacated the judgment that Braidwood is constitutionally entitled to a Title VII exemption; and vacated the judgment regarding the scope-of-Title-VII claims as a matter of law. The court reasoned that under the facts presented, it cannot determine a more appropriate, limited class definition for any of the classes presented here. Accordingly, the court held that both Braidwood and Bear Creek have standing and bring individual claims. Further, the court explained that the EEOC failed to show a compelling interest in denying Braidwood, individually, an exemption. The agency does not even attempt to argue the point outside of gesturing to a generalized interest in prohibiting all forms of sex discrimination in every potential case. View "Braidwood Management v. EEOC" on Justia Law

Texas and Missouri filed suit seeking to compel DHS to employ the $2.75 billion Congress allocated “for the construction of [a] barrier system along the southwest border” before those funds expire. The district court dismissed Texas for “claim splitting,” held that Missouri did not have standing to sue, and denied the States’ motion for a preliminary injunction as moot. The states appealed.On appeal, the Fifth Circuit reversed and remanded with instructions for the district court to "expeditiously consider the States’ motion for a preliminary injunction." The court explained Texas should not have been dismissed for claim splitting because Texas’s Article III standing confers federal jurisdiction. In terms of causation, Texas needs only to have alleged facts showing the Federal Defendants’ conduct is a cause-in-fact of the injury that the State asserts. Here, Texas claimed that border barriers (i) reduce illegal entries in areas where constructed, and (ii) increase the rate at which illegal aliens are detected and apprehended.However, the court declined to order the states' requested remedy, instead remanding the case to the district court. View "State of Missouri v. Biden" on Justia Law

Plaintiffs appealed the Rule 12(b)(6) dismissal of their complaint, alleging that the City of New Braunfels’s zoning regulation banning short-term rentals of residential properties in certain areas of the city is unconstitutional. The district court ordered dismissal.   The Fifth Circuit vacated and remanded. The court held that Plaintiffs are entitled to engage in discovery in an attempt to surmount the currently high bar for challenging local zoning ordinances under the Constitution. View "Marfil v. City of New Braunfels" on Justia Law

The National Marine Fisheries Service promulgated a rule requiring shrimp trawlers 25 feet or longer operating in offshore waters from North Carolina to Texas to install turtle excluder devices (TEDs), subject to a few preconditions. In 2012, NMFS proposed a more restrictive rule requiring TEDs for skimmer trawlers. The Final Rule required TEDs on all skimmer trawlers over 40 feet, including those that operate inshore. Louisiana’s Department of Wildlife and Fisheries (LDWF) sued NMFS under the Administrative Procedure Act, challenging the Final Rule as arbitrary and capricious. Louisiana moved for summary judgment, focusing on the merits of its claims. NMFS opposed and filed a cross-motion for summary judgment. The district court granted NMFS’s motion, holding that Louisiana had not carried its summary judgment burden to establish standing.   The Fifth Circuit affirmed. The court held that based on the record and procedural history of the case, the district court did not err in concluding that Louisiana failed to establish that it has standing to challenge the NMFS’s, Final Rule. The court reasoned that while the Final Rule’s EIS noted that the rule would adversely affect the shrimping industry across the Gulf of Mexico, Louisiana failed to provide evidence, particularly substantiating the rule’s impact on its shrimping industry or, ergo, “a sufficiently substantial segment of its population.” Nor does Louisiana’s invocation of the “special solicitude” afforded States in the standing analysis rescue this argument, or for that matter, the State’s other arguments. View "Louisiana State v. NOAA" on Justia Law