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

Margaret Woods, proceeding without an attorney, sued her former employer STS Services, L.L.C., after being terminated from her job. In her Third Amended Complaint, Woods alleged that she was fired because she is a black woman and replaced by white men. Earlier versions of her complaint included claims for breach of contract and race discrimination under 42 U.S.C. § 1981, which she abandoned, leaving only claims of race and sex discrimination under Title VII. Woods did not provide factual details about her qualifications for the position from which she was terminated.The United States District Court for the Northern District of Texas reviewed Woods’s successive complaints. Each time, the district court dismissed her complaints for failure to state a claim but allowed her opportunities to amend and refile. Woods submitted her Second Amended Complaint late, which was also dismissed. Her Third Amended Complaint was timely, but again found deficient for failing to plead facts regarding her qualifications. The court gave her another chance to amend, but Woods did not file a Fourth Amended Complaint within the deadline, or at all. The district court ultimately dismissed the case with prejudice and entered judgment in favor of STS Services, assessing costs against Woods.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The appellate court held that Woods failed to state a Title VII claim because her complaint did not include sufficient factual allegations to establish that she was qualified for her position, a necessary element of a prima facie case under Title VII. The Fifth Circuit also found that the district court did not abuse its discretion in dismissing Woods’s complaint with prejudice after repeated deficiencies and failures to amend. The judgment of the district court was affirmed. View "Woods v. STS Services" on Justia Law

Police officers in Rosenberg, Texas conducted a high-risk stop of a white Dodge Charger matching the description of a vehicle involved in a report of armed suspects. The only occupants were Michael Lewis and Regina Armstead, an elderly couple. Lewis had a dialysis-related stent in his left forearm, which could be damaged by placing handcuffs on that arm. During the stop, Lewis was handcuffed for about six minutes, reportedly experiencing pain. He later discovered his stent had been damaged and required surgery. Armstead informed an officer that Lewis was a dialysis patient, and Lewis claimed he told officers about his condition both before and after being handcuffed, though his statements were inconsistent.Lewis and Armstead filed suit in the United States District Court for the Southern District of Texas against the City, the police department, and the officers, including an excessive force claim. After a magistrate judge’s recommendation, the district court granted qualified immunity on most claims but denied it on Lewis’s excessive force claim against the five officers, finding a genuine dispute of material fact as to when the officers were informed about Lewis’s medical condition. The officers appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of qualified immunity de novo. The Fifth Circuit held that the officers did not violate any clearly established law by briefly handcuffing Lewis during a high-risk stop, regardless of whether they had advance notice of his medical condition. The court found that relevant precedent did not place the constitutional question beyond debate under the circumstances, and thus, the officers were entitled to qualified immunity. The Fifth Circuit reversed the district court’s denial of qualified immunity. View "Lewis v. Delgado" on Justia Law

The case concerns an incident in which Yoni Perdomo, after being terminated from a residential remodeling job, returned to the worksite to retrieve his tools and seek unpaid wages. When the general contractor refused payment and asked Perdomo to leave, Perdomo called the police. Officers from the League City Police Department arrived and, after a brief interaction during which Perdomo became frustrated, Perdomo physically slammed his back into one of the officers. Officer Rector then tackled Perdomo to the ground, resulting in Perdomo suffering serious injuries when his head struck the concrete. The officers called for medical assistance within seconds.Perdomo filed suit in the United States District Court for the Southern District of Texas against the officers, the police department, and the city, alleging violations under 42 U.S.C. § 1983 and state law claims, including excessive force, false arrest, and deliberate indifference to medical needs. The district court dismissed all claims under Rule 12(b)(6), finding that body camera footage contradicted Perdomo’s account and showed that the officers acted reasonably, entitling them to qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The appellate court agreed that the video evidence contradicted Perdomo’s version of events, showing him as aggressive and not compliant. The court held that the officers’ use of force was reasonable under the circumstances, that probable cause existed for Perdomo’s arrest, and that the officers were not deliberately indifferent to his medical needs. The city and police department could not be liable absent an underlying constitutional violation. State law claims were also barred by immunity. The Fifth Circuit affirmed the district court’s dismissal of all claims. View "Perdomo v. City of League City, TX" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

After the Texas Legislature passed the Election Protection and Integrity Act of 2021 (“S.B.1”), a sweeping law that amended numerous aspects of the state’s election procedures, multiple groups of plaintiffs—including civil rights and voter advocacy organizations—challenged thirty-eight provisions of the law. They alleged violations of various constitutional amendments, the Voting Rights Act (VRA), the Americans with Disabilities Act (ADA), and the Rehabilitation Act, naming state officials including the Texas Secretary of State and Attorney General as defendants.In the United States District Court for the Western District of Texas, the defendants moved to dismiss on grounds of sovereign immunity and lack of standing. The district court addressed the motions on a provision-by-provision basis, concluding that the Secretary and Attorney General were sufficiently connected to the enforcement of most challenged provisions to overcome sovereign immunity under Ex parte Young, and that plaintiffs had standing to sue. It denied the motions to dismiss for the majority of the claims, although it dismissed others as moot, for lack of standing, or for failure to state a claim. The defendants appealed the denials.The United States Court of Appeals for the Fifth Circuit held it had appellate jurisdiction over the interlocutory sovereign immunity appeals. On the merits, the Fifth Circuit affirmed in part and reversed in part. It held that the VRA claims were not barred by sovereign immunity. For the constitutional and other statutory claims brought under 42 U.S.C. § 1983, the court determined that the Secretary of State is a proper defendant only for those provisions she directly enforces—such as those involving the design of forms and sanctioning of registrars—and not for those enforced by other officials. Similarly, it held the Attorney General could be sued only for one provision authorizing civil penalties. The court affirmed standing for claims against provisions enforced by these officials. View "Un del Pueblo Entero v. Nelson" on Justia Law

On July 29, 2007, Noel Dean’s wife, Shannon, died from a gunshot wound at their home after she became severely intoxicated and after Noel confronted her with evidence of an affair. Noel reported that Shannon shot herself, but law enforcement suspected homicide. The next day, Dr. Darshan Phatak, an assistant medical examiner, performed the autopsy. Initially, he could not determine whether the death was a homicide or suicide and marked the cause as “pending.” After meeting with colleagues and reviewing police interviews and other evidence, Dr. Phatak concluded the gun’s orientation at the time of the shooting was inconsistent with Noel’s account and classified the death as a homicide in the official autopsy report. This report contributed to Noel’s arrest and indictment for murder. During a subsequent trial, photographic overlays created by Dr. Phatak’s supervisor suggested the gun orientation matched Noel’s story, prompting a change in the autopsy report’s classification to “undetermined” and a dismissal of charges.Noel Dean then filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging Dr. Phatak intentionally fabricated the autopsy report. The United States District Court for the Southern District of Texas denied Dr. Phatak’s summary judgment motion based on qualified immunity, relying on allegations rather than evidence. On initial appeal, the United States Court of Appeals for the Fifth Circuit vacated and remanded for proper consideration of the summary judgment record. After further briefing and significant delay, the district court again denied summary judgment, applying a “deliberate indifference” standard.On this second interlocutory appeal, the United States Court of Appeals for the Fifth Circuit held that the district court applied the wrong legal standard by using a “deliberate indifference” test rather than determining whether a rational juror could find Dr. Phatak intentionally misstated his conclusions. The appellate court vacated the denial of summary judgment and remanded for reconsideration under the correct standard. View "Dean v. Phatak" on Justia Law

Three business entities and individuals associated with the operation of a retail store in Cedar Park, Texas, were subject to enforcement under a city ordinance banning “head shops”—stores selling items commonly used to ingest or inhale illegal substances. After receiving notices from the City, two of the appellants were charged in municipal court and fined for violating the ordinance, while the third appellant, a related business entity, was not charged. Following the municipal court’s judgment, the two charged parties appealed for a trial de novo in the county court, which annulled the municipal court’s judgment and began new criminal proceedings. They also pursued state habeas relief, which was still ongoing at the time of this appeal.Separately, the appellants filed a lawsuit in the United States District Court for the Western District of Texas, challenging the ordinance’s validity and constitutionality under federal and state law, and seeking declaratory and injunctive relief. The district court dismissed all claims as barred by the doctrine announced in Heck v. Humphrey, which precludes certain civil claims that would imply the invalidity of existing criminal convictions. The district court also dismissed a distinct claim related to termination of utility services.On appeal, the United States Court of Appeals for the Fifth Circuit held that because the municipal court’s judgments were annulled by the trial de novo and criminal proceedings were still pending under Texas law, there were no outstanding convictions to trigger the Heck bar. Thus, the Fifth Circuit reversed the district court’s dismissal of the claims challenging the ordinance and remanded for further proceedings. The court affirmed the district court’s dismissal of the standalone water termination claim, as the appellants had disclaimed any intent to pursue it. View "Kleinman v. City of Cedar Park" on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

The plaintiffs in this case are entities that own and operate a four-story building in Kemah, Texas. The building houses a bar, residential rental units, and a food truck. The dispute began when, in July 2021, the city issued a zero-occupancy notice for the building after an inspection found multiple safety hazards, prohibiting anyone except the owner and repair contractors from entering. Plaintiffs allege this deprived them of almost all economic use of the property. Separately, the city took enforcement action against the food truck, culminating in its removal from the property in October 2021. Plaintiffs challenged the food truck towing in state court, but ultimately dropped their appeal. They then sued the city in federal court, raising federal and state takings, due process, and equal protection claims regarding both the zero-occupancy notice and the food truck towing, and sought declaratory relief.The United States District Court for the Southern District of Texas granted the city’s motion to dismiss. The court found the claims related to the zero-occupancy notice were not ripe because plaintiffs had not pursued available administrative appeals to the city council, as allegedly required by city ordinances. The court dismissed the food truck claims on the merits, and dismissed the request for declaratory relief because no substantive claims remained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred in dismissing the zero-occupancy notice claims as unripe. The appellate court determined that the city’s issuance of the zero-occupancy notice constituted a sufficiently final decision for purposes of ripeness and that exhaustion of administrative remedies is not required for claims under 42 U.S.C. § 1983. The court reversed the dismissal of the zero-occupancy notice claims and remanded those claims, including the related request for declaratory relief, for further proceedings. However, the court found that the plaintiffs had waived their food truck claims by failing to adequately brief them on appeal and affirmed their dismissal. View "T&W Holding v. City of Kemah, Texas" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law