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

David Wood was convicted of capital murder and sentenced to death in 1992 for the brutal murders of six females in 1987. The victims were found buried near El Paso, and evidence indicated that Wood had sexually assaulted them before killing them. Wood's conviction and sentence were affirmed by the Texas Court of Criminal Appeals (CCA). Over the years, Wood pursued extensive litigation in state and federal courts, including multiple motions for post-conviction DNA testing under Chapter 64 of the Texas Code of Criminal Procedure. The trial court granted some of his motions, but the results did not exonerate him. Subsequent motions were denied, and the CCA affirmed these denials, concluding that Wood had engaged in a pattern of piecemeal litigation and delay.Wood then filed a 42 U.S.C. § 1983 suit in the United States District Court for the Western District of Texas, alleging that the CCA's construction of Chapter 64 violated his procedural due process rights. He claimed that the CCA's consistent denial of DNA testing rendered the state-created testing right illusory and that the CCA's interpretation of the statute's unreasonable-delay provision was novel and unforeseeable. The district court dismissed Wood's complaint and denied his motion to stay his execution.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wood lacked standing for his first claim because a favorable ruling would not substantially likely lead to DNA testing. For his second claim, the court found it meritless, as the CCA's interpretation of the unreasonable-delay provision was neither novel nor unforeseeable. Consequently, the Fifth Circuit affirmed the district court's order and judgment and denied Wood's renewed motion to stay his execution. View "Wood v. Patton" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

In February 2020, Nicolas Robertson was shot and killed in Jackson, Mississippi. Two months later, Samuel Jennings, who was arrested for burglary and grand larceny, provided a statement to Detective Jacquelyn Thomas implicating Desmond Green in the murder. Green was subsequently indicted by a grand jury and detained for nearly two years. In March 2022, Jennings recanted his statement, admitting he was under the influence of drugs when he implicated Green and had no actual knowledge of the murder. Green was released from jail after the charges were dismissed.Green sued Detective Thomas under 42 U.S.C. § 1983, alleging violations of his Fourth and Fourteenth Amendment rights, including malicious prosecution and false arrest without probable cause. The United States District Court for the Southern District of Mississippi denied Detective Thomas qualified immunity at the motion-to-dismiss stage, allowing Green's claims to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Green sufficiently alleged violations of his clearly established Fourth Amendment right against false arrest and his Fourteenth Amendment due process rights. The court found that Detective Thomas allegedly manipulated a photo lineup and withheld exculpatory evidence from the grand jury, which could have influenced the grand jury's decision to indict Green. However, the court granted Detective Thomas qualified immunity on Green's malicious prosecution claim, as the constitutional tort of malicious prosecution was not clearly established in the Fifth Circuit at the time of Green's arrest.The Fifth Circuit affirmed the district court's denial of qualified immunity for Green's false arrest and due process claims but reversed the denial of qualified immunity for the malicious prosecution claim. View "Green v. Thomas" on Justia Law

Annette Rodriguez, the plaintiff, served as the Director of the City of Corpus Christi and Nueces County Public Health District. Her salary was split between the City and the County. In 2019, the City increased her salary to 90% of the market rate. During the COVID-19 pandemic, Rodriguez requested and initially received overtime pay, but the City later stopped these payments. Rodriguez faced several allegations of policy violations and creating a hostile work environment, leading to a disciplinary memorandum. Despite a positive evaluation from the County, the City terminated her in 2022 and hired a new director.Rodriguez sued the City in the United States District Court for the Southern District of Texas, claiming violations under the Equal Pay Act, Fair Labor Standards Act (FLSA), Title VII, and 42 U.S.C. § 1983. The district court dismissed her Section 1983 claim on the pleadings, finding she did not allege a constitutionally protected interest in continued employment. The court granted summary judgment to the City on the remaining claims, concluding Rodriguez was exempt from FLSA overtime pay requirements, did not establish the equal-work or equal-pay prongs of her EPA claim, and failed to identify a proper comparator for her Title VII claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's rulings, agreeing that Rodriguez did not engage in protected activity under the FLSA, failed to identify a proper comparator for her Title VII and EPA claims, and did not establish pretext for retaliation. The court also found that Rodriguez remained an exempt employee despite receiving additional overtime pay temporarily. The court concluded that the City paid Rodriguez on a salary basis, maintaining her exempt status under the FLSA. View "Rodriguez v. City of Corpus Christi" on Justia Law

A neighbor called the Fort Worth Police Department at 2:25 a.m. on October 12, 2019, to report that Atatiana Jefferson's front door was open, which was unusual. Officer Aaron Dean and another officer responded, arriving at 2:28 a.m. and 2:29 a.m., respectively. Following protocol, they parked out of view and did not use emergency lights or sirens. They conducted a perimeter sweep of the house, using flashlights to look for signs of a break-in. Jefferson, who was home with her nephew, noticed someone outside and approached the window. Dean, without announcing himself as an officer, commanded Jefferson to show her hands and then fired a shot, killing her.The United States District Court for the Northern District of Texas denied Dean's motion to dismiss based on qualified immunity and stayed discovery. Dean appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's judgment regarding the excessive force claim, holding that Dean's use of deadly force without warning was objectively unreasonable under clearly established law. However, the court reversed the district court's judgment on the unreasonable search claim, finding that Dean was performing a community caretaking function and that there was no clearly established law indicating his actions were unreasonable. The case was remanded for further proceedings consistent with the opinion. View "Bakutis v. Dean" on Justia Law

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" 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

Following public outcry over "Pride Month" displays in St. Tammany Parish's public libraries, the Parish Council passed a resolution that vacated the terms of the Library Board of Control members, staggered those terms in accordance with Louisiana law, and appointed new Board members. Three ousted Board members—Anthony Parr, Rebecca Taylor, and William McHugh, III—sued under 42 U.S.C. § 1983, asserting viewpoint-discrimination, free-speech, retaliation, and substantive-due-process claims against the Council and Councilman David Cougle. They sought declaratory and injunctive relief to prevent the resolution from taking effect.The United States District Court for the Eastern District of Louisiana ruled that the legislative privilege was inapplicable because the resolution was not "legislative" in nature. Defendants brought an interlocutory appeal challenging this ruling. Before addressing the legislative privilege issue, the United States Court of Appeals for the Fifth Circuit examined whether the plaintiffs had standing to bring their claims.The Fifth Circuit concluded that the plaintiffs lacked standing. The court found that the plaintiffs' alleged speech-related injuries were not particularized, as they were tied to their positions as Board members and affected all members equally. Additionally, the court determined that the plaintiffs' alleged reputational injuries were neither fairly traceable to the defendants' conduct nor redressable by a favorable decision. Consequently, the court vacated the district court's order and remanded with instructions to dismiss the plaintiffs' claims for lack of subject matter jurisdiction. View "Parr v. Cougle" on Justia Law

George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law