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

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

The Fifth Circuit dismissed plaintiff's appeal of two district court orders based on lack of jurisdiction. The first order requires that plaintiff pay costs under Federal Rule of Civil Procedure 41(d), and the second administratively closes the case pending such payment. The court held that these orders were not final judgments, and thus did not fall within any exception to the final judgment rule and mandamus relief was inappropriate. View "Sammons v. Economou" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of an action, seeking to compel compliance with the terms of the parties' retail installment contract, based on lack of personal jurisdiction. The court held that Conn failed to establish a prima facie case that the district court had personal jurisdiction over defendant where he entered into the retail installment contract with Conn at its Tennessee store, the contract provided that it would be governed by Tennessee and federal law, and the arbitration clause would be governed by the Federal Arbitration Act. Therefore, other than defendant entered into a contract with a Texas entity, there was no evidence in the record that defendant engaged with the Texas forum. Furthermore, Conn has not demonstrated any evidence that defendant purposefully availed himself of the Texas forum. View "Conn Appliances, Inc. v. Williams" on Justia Law

After Double Eagle filed for Chapter 11 bankruptcy, it filed suit against MarkWest and Ohio Gathering on a contract claim in Louisiana federal court. Double Eagle then assigned its claim against defendants to one of its creditors.The Fifth Circuit vacated the district court's judgment and held that the district court erred by failing to apply the time-of-filing rule to 28 U.S.C. 1334(b) in this lawsuit that was related to a bankruptcy when filed, but then the bankruptcy connection was later dissolved. The court explained that this longstanding rule promoted efficiency and thus it would be wasteful if post-filing changes in the facts determining jurisdiction required dismissal of a case to which the parties and court had already devoted resources. In this case, the related-to-bankruptcy jurisdiction that existed at the outset of this case never went away. The court also held that failing to focus on the time of filing also infected the district court’s personal jurisdiction analysis, and the section 1334(b) jurisdiction that existed when this case was filed thus means there is both subject matter and personal jurisdiction. The court rejected defendants' remaining claims and remanded for further proceedings. View "Double Eagle Energy Services, LLC v. MarkWest Utica EMG, LLC" on Justia Law

The Fifth Circuit affirmed the district court's denial of JMPC's motion to compel certain post-judgment discovery. The court held that, although the district court's reliance on the June 2011 date as relevant to DTC's knowledge of any potential claims by JPMC was clearly erroneous, the error was harmless. The court also held that the district court did not abuse its discretion by tying discovery to a time period associated with the Cathay agreement; the district court did not abuse its discretion by limiting discovery to the 2012 breach and the amount of the judgment specifically tied to that one breach; and the district court's proportionality determination was reasonable. View "JP Morgan Chase Bank, N.A. v. Datatreasury Corp." on Justia Law

Plaintiffs filed suit challenging Mississippi Senate Bill 2162, claiming that it violated the Fourteenth Amendment's Equal Protection Clause and the equal protection component of the state constitution. The district court affirmed the magistrate judge's grant in part of plaintiffs' motion to enforce subpoenas on eight state legislators, ordering them to produce a privilege log and any relevant information previously shared with third parties.The Fifth Circuit held that, to the extent the order required the Legislators to comply with Request 3 in the subpoenas issued by the JMAA plaintiffs, the district court abused its discretion in ordering the Legislators to comply with a production order unrelated to those plaintiffs' claims. The court also held that, because the individual plaintiffs were without standing to pursue the equal protection claim, the district court lacked jurisdiction to enforce their subpoenas. Accordingly, the court vacated and remanded with instructions to dismiss without prejudice, for want of jurisdiction, the equal protection claim of the intervenors' complaint. View "Stallworth v. Bryant" on Justia Law