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

Plaintiff filed suit against UTMB and his supervisors for various claims brought under Title VII of the Civil Rights Act, the Family and Medical Leave Act (FMLA), and the Americans with Disabilities Act (ADA). The district court granted summary judgment to defendants on all claims.The Fifth Circuit dismissed the appeal for want of prosecution for plaintiff's failure to adhere to the federal and local rules of appellate procedure. In this case, most of the documents produced in plaintiff's supplemental appendix were not first introduced to the district court and were therefore not part of the record on appeal; plaintiff's motion was unnecessary with respect to the documents that did appear in the district court record but were not in the record excerpts appendix; the brief did not have the technical record citations that were required of appellate briefings; and plaintiff's non-compliance was prejudicial to defendants. View "Arredondo v. University of Texas Medical Branch at Galveston" on Justia Law

Plaintiffs, Second Amendment advocates, filed suit seeking to prevent the State Department from blocking their efforts to publish plans for how to assemble a firearm using a 3D printer. Plaintiffs settled with the State Department and then voluntarily dismissed the suit. Now plaintiffs seek to revive their Texas suit under Federal Rule of Civil Procedure 59(e) in response to a nationwide injunction against enforcement of the settlement issued by the Western District of Washington.The Fifth Circuit declined plaintiffs request to revive the lawsuit, holding that Rule 59(e) authorizes motions to alter or amend judgments, not to revive lawsuits. The court explained that the initiation and prosecution of the Washington suit did not render any action by the district court in Texas erroneous, let alone manifestly erroneous. View "Defense Distributed v. United States" on Justia Law

Plaintiffs filed a wrongful death action against defendants, alleging inter alia, claims for negligence, premises liability, and breach of warranty. On appeal, plaintiffs argued that the Texas court erred in not exercising personal jurisdiction over PNK because a non-resident company, like PNK, may be subjected to general jurisdiction for its targeted advertising in the forum state.The Fifth Circuit affirmed and held that the Southern District of Texas properly held that it lacked personal jurisdiction over PNK and appropriately transferred this action to Louisiana. In this case, PNK is a limited liability company domiciled in Louisiana, and PNK's corporate contacts with Texas are not of the exceptional nature such that PNK could be found to be "at-home" in Texas. The court rejected plaintiffs' claims to the contrary and held that it could not exercise general jurisdiction over PNK. View "Frank v. P N K (Lake Charles) LLC" on Justia Law

The Fifth Circuit affirmed the district court's denial of discretionary review of five awards made to Walmart under the Settlement Agreement arising from the 2010 Deepwater Horizon disaster. The court held that there was no showing of a misapplication or contradiction of the Settlement Agreement requiring the district court's review. In this case, the Claims Administrator conducted a searching review of the financial statements Walmart provided from both its old and new accounting system, and the PWC accountants brought specific clarification questions to Walmart regarding the changes. Furthermore, Walmart responded to the satisfaction of the Claims Administrator.The court rejected BP's claim that there was a split Appeal Panels on how to address changes in accounting systems like the one at issue here. The court saw BP's claim as one challenging the Appeal Panels' discretionary decision that raises the correctness of a discretionary administrative decision on the facts of a single claimant's case, and held that the district court's denial of a request for discretionary review of such a decision was not an abuse of discretion. View "BP Exploration & Production, Inc. v. Claimant ID 100354107" on Justia Law

Plaintiffs, six Travis County Sheriff's Office detectives, filed suit alleging that they were entitled to overtime pay under the Fair Labor Standards Act (FLSA). The county argued that plaintiffs were exempt as both executive and highly-compensated employees. The district court granted judgment for plaintiffs. Then the district court later ruled as a matter of law that plaintiffs were paid a salary, vacated the jury's finding on the first requirement of the exemptions, and granted plaintiffs' request for a new trial. Plaintiffs sought reconsideration, contending that they had conditionally asked for a new trial on the management issue, an element of the executive exemption and first-responder exception, not on the office-work issue, which is part of the highly-compensated-employee exemption. Plaintiffs then moved for reentry of judgment in their favor. Because plaintiffs did not want a new trial, the district court entered a final judgment.Rejecting the parties' jurisdictional challenges, the Fifth Circuit affirmed and held that it had appellate jurisdiction. The court also held that plaintiffs' failure to challenge the timeliness of the Rule 50(b) motion in the district court means that they have forfeited that objection, and the district court had jurisdiction to decide the motion for judgment as a matter of law. The court explained that a new trial was needed to answer the additional questions about whether plaintiffs were exempt and, by prevailing on a Rule 50(b) motion, the county did not somehow lose its right to assert its defenses.On the merits, the court held that the district court properly held as a matter of law that the county paid plaintiffs on a salary basis. Although the ruling did not fully resolve whether plaintiffs were entitled to overtime pay, the court stated that years of litigation never answered that ultimate question. View "Escribano v. Travis County" on Justia Law

ICP filed suit against Treasury and OCC, alleging claims under Section 3608 of the Fair Housing Act (FHA) and the Fifth Amendment. ICP alleged that defendants failed to regulate the federal Low-Income Housing Tax Credit program so as to promote fair housing. The district court granted summary judgment for defendants on three grounds.The court held that ICP lacked standing to sue either OCC or Treasury, because ICP could not establish causation or redressability. In this case, neither defendant regulates ICP. Accordingly, the court affirmed the district court's grant of summary judgment as to ICP's claims against OCC and Section 3608 claims against Treasury. Because the district court reached the merits of ICP's Fifth Amendment claim against Treasury, the court vacated the summary judgment and rendered a judgment of dismissal for want of jurisdiction. View "Inclusive Communities Project v. Department of Treasury" on Justia Law

This case stemmed from plaintiff's action alleging that NASA discriminated against her. The Fifth Circuit held that plaintiff pleaded her way out of federal court by attempting to litigate her claims in several mutually exclusive forums. In this case, plaintiff pleaded her way out of the Federal Circuit by attempting to bifurcate her discrimination and non-discrimination claims.Plaintiff first chose to pursue her mixed case before the MSPB rather than filed an EEO complaint with NASA ODEO. After the MSPB rejected her mixed case, she could have sought review in federal district court, but could not go back and choose to file an EEO complaint. The court explained that plaintiff could have then dropped her mixed case and pursued only the Civil Service Reform Act (CSRA) claim before the Federal Circuit; pursued the mixed case in federal district court; or pursued the mixed case in the EEOC. Although federal law allowed plaintiff to choose one of these options, she tried to choose all three. Consequently, the court held that plaintiff deprived any court of subject-matter jurisdiction over her appeal from the MSPB; she pleaded her way out of the Federal Circuit; and she missed the deadline to file in district court View "Punch v. Bridenstine" on Justia Law

After IntegraNet filed suit against a former-employee owner in state court and the case was removed to federal court, IntegraNet then filed suit against the former-employee owner in state court for another claim. The district court consolidated the cases and sua sponte barred IntegraNet from filing another case against appellees without the judge's permission.The Fifth Circuit held that the district court abused its discretion in exercising jurisdiction in light of Enochs v. Lampasas County, 641 F.3d 155, 161 (5th Cir. 2011), which held that courts are instructed to examine their jurisdiction at every stage of the litigation; consolidation was inappropriate, because the primary lawsuit lacked a basis for federal jurisdiction; and the lack of federal jurisdiction also rendered the pre-filing injunction improper. Accordingly, the court reversed the consolidation order, vacated the injunction, and remanded both claims with instructions to the district court to remand the Texas state law claims to the Texas state court from which the cases were removed. View "Integranet Physician Resource v. Texas Independent Providers" on Justia Law

Plaintiff, a lawyer who is self-described as a monarch and a deity, brought claims on behalf of an Indian tribe alleging that defendants have, among other misdeeds, monopolized "intergalactic foreign trade." The district court dismissed the action based on sovereign immunity. The Fifth Circuit affirmed the district court's dismissal on an alternative basis, holding that plaintiff's claims were frivolous and the district court lacked jurisdiction to entertain them. View "Atakapa Indian de Creole Nation v. Louisiana" on Justia Law

Plaintiffs, an abortion clinic and two of its doctors, brought a cumulative-effects challenge to Louisiana's laws regulating abortion, arguing that the provisions taken as a whole were unconstitutional, even if the individual provisions were not. The district court denied Louisiana's motion to dismiss, but certified its order for interlocutory appeal under 28 U.S.C. 1292(b). The district court then rescinded its certification so that plaintiffs could amend their complaint. The district court again denied Louisiana's motion to dismiss. Louisiana subsequently petitioned the Fifth Circuit for mandamus relief.Although the district court's failure to consider the state's jurisdictional challenges and the inadequacy of a later appeal support issuance of the writ, the court nonetheless exercised its discretion not to issue it at this time. In this case, it was not clear from the district court's order how it would resolve the state's jurisdictional challenge, and much of the state's argument in its mandamus petition went beyond jurisdiction. Therefore, the court elected to allow the district court to consider the state's jurisdictional challenges in the first instance. View "In re: Rebekah Gee" on Justia Law