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

Jessie Grace was convicted of second-degree murder in 1994 and sentenced to life in prison without the possibility of probation or parole. The Louisiana Fifth Circuit affirmed his conviction. Over the next 18 years, Grace filed several post-conviction relief applications, all of which were denied until 2012, when he was granted leave to reopen his federal proceedings based on newly discovered evidence. Grace obtained state grand jury testimony that revealed discrepancies between the grand jury and trial testimonies of two key witnesses: Sergeant Snow and Michelle Temple. These discrepancies suggested that another individual, Darrick Hudson, might have been involved in the crime.In 2015, Grace filed a third application for post-conviction relief in state trial court, alleging Brady violations based on the grand jury testimony. The state trial court granted his application, vacated his conviction, and ordered a new trial. The State appealed, and the Louisiana Fifth Circuit reversed the trial court's decision, reinstating Grace's life sentence. The Louisiana Supreme Court denied Grace's subsequent writ application in 2019. Grace then filed a second supplemental application in federal district court, asserting a Brady claim. The district court granted relief, but the United States Court of Appeals for the Fifth Circuit vacated the order and remanded for further proceedings.On remand, the district court again granted Grace's habeas relief, finding that the state court erred in its consideration of the materiality of the suppressed evidence. The State appealed, and the Fifth Circuit reviewed the case. The Fifth Circuit determined that the state court's decision was not an unreasonable application of clearly established federal law and that the suppressed evidence was not material enough to undermine confidence in the verdict. The Fifth Circuit reversed the district court's decision and denied Grace's application for habeas relief. View "Grace v. Hooper" on Justia Law

Gabino Ramos Hernandez was involved in a traffic stop on July 20, 2016, where he was stopped by Laurel Police Department Officer David Driskell for failing to stop at a stop sign. Hernandez's brother, who appeared intoxicated, was also stopped. Officer Driskell called Immigration and Customs Enforcement (ICE) agents for translation assistance. Hernandez, who was initially waiting, decided to leave the scene and was pursued by ICE agents. During the pursuit, ICE Agent Phillip Causey shot Hernandez, who alleges he had his hands raised in surrender.Hernandez filed a lawsuit against Causey under 42 U.S.C. § 1983 and Bivens, along with other claims. The United States District Court for the Southern District of Mississippi dismissed the Bivens claim, stating it would expand Bivens to a new context, and dismissed the § 1983 claim, finding Causey did not act under color of state law. The court also denied Hernandez's motion to amend the complaint, deeming further amendment futile.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, agreeing that Hernandez's claim presented a new context and that alternative remedies existed. The court also affirmed the dismissal of the § 1983 claim, concluding that Hernandez failed to allege that Causey acted under color of state law or that there was a conspiracy between Causey and state officials. The court upheld the denial of Hernandez's motion to amend the complaint, as further amendment would be futile. View "Hernandez v. Causey" on Justia Law

Enriqueta Diaz, a former county judge and resident of Maverick County, opposed the issuance of certificates of obligation for water and sewer improvements by the Maverick County Commissioners Court. She collected signatures on a petition to force an election on the issue. Despite her petition, the commissioners decided to issue the certificates without holding an election. During the meeting, Diaz heckled the commissioners, leading County Judge English Cantu to hold her in contempt and order her removal. Diaz was detained outside in the rain for several hours and later sentenced to 24 hours in jail, though she was released without being confined.Diaz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Texas, seeking damages for false imprisonment and bystander liability against County Judge English Cantu and three county commissioners. The district court denied the defendants' motion to dismiss, rejecting their claims of state sovereign immunity, judicial immunity, and qualified immunity. The defendants appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that constitutional county judges in Texas are not entitled to state sovereign immunity as they are considered local rather than state officers. The court also determined that English Cantu was not entitled to judicial immunity because he was acting in an administrative capacity, not a judicial one, during the commissioners court meeting. Additionally, the court found that English Cantu was not entitled to qualified immunity because he acted without discretionary authority in holding Diaz in contempt. However, the court reversed the district court's denial of qualified immunity for the commissioners on the bystander liability claims, as the law was not clearly established that they had a duty to intervene. The case was remanded for further proceedings. View "Diaz v. Cantu" on Justia Law

Alejandro Martinez was walking home when Officer Cantu stopped him for walking on the wrong side of the street, in violation of the Texas Transportation Code. Martinez initially complied but then walked away. Cantu took Martinez to the ground to handcuff him. Other officers arrived, and Martinez was taken to a hospital, where he was found to have no serious injuries and was cleared for jail.Martinez sued the City of Rosenberg and several officers under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force. The United States District Court for the Southern District of Texas dismissed the municipal liability claim against the City for failure to state a claim under Monell v. Department of Social Services of the City of New York. The court also granted summary judgment for the officers on qualified immunity grounds, finding no constitutional violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the Monell claim, agreeing that Martinez's complaint was conclusory and lacked factual support. The court also affirmed the summary judgment for the officers, finding that Officer Cantu had probable cause to arrest Martinez for violating the Texas Transportation Code and that the force used was reasonable. The court noted that Martinez's injuries were de minimis and that the bystander liability claim could not stand without an underlying constitutional violation. The court concluded that the officers were protected by qualified immunity and affirmed the district court's judgment. View "Martinez v. City of Rosenberg" on Justia Law

Andre Louis Keller drove to a permanent immigration checkpoint where a Customs & Border Protection (CBP) canine alerted to his vehicle. Upon searching, agents found an alien unlawfully present in the United States concealed under luggage. Keller conditionally pleaded guilty and appealed the district court’s denial of his motion to suppress the evidence found in the vehicle.The United States District Court for the Southern District of Texas held a hearing on Keller’s motion to suppress. Testimonies were provided by CBP Agent Jesse Sandoval, Matthew B. Devaney from CBP’s Canine Academy, and Andre Falco Jimenez, a private police dog trainer. The district court denied Keller’s motion, leading to his conditional guilty plea. Keller was sentenced to 20 months in prison and 3 years of supervised release. He then appealed the suppression ruling.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that stopping a vehicle for brief questioning at a permanent immigration checkpoint is not a Fourth Amendment search and does not require probable cause. The court found that the canine’s alert provided probable cause to search Keller’s vehicle. The court also concluded that the canine’s actions did not constitute an unlawful search and that the district court did not err in its ruling. The Fifth Circuit affirmed the district court’s denial of Keller’s motion to suppress. View "United States v. Keller" on Justia Law

Cedric Allen Ricks was convicted of capital murder in Texas state court for killing his girlfriend and her eight-year-old son and was sentenced to death. After his direct appeal and state habeas petition were denied, Ricks filed a federal habeas petition, which the district court also denied, including a certificate of appealability (COA).Ricks sought a COA from the United States Court of Appeals for the Fifth Circuit on several claims. The district court had denied his Batson claim, which alleged racial discrimination in jury selection, finding no prima facie case of discrimination and accepting the prosecution's race-neutral justifications. The district court also found no pattern of racially disparate questioning. The Fifth Circuit agreed, noting that reasonable jurists would not find the district court's assessment debatable or wrong, and thus denied the COA on this claim.Ricks also claimed ineffective assistance of appellate counsel for not raising the Batson claim on appeal. The state court had denied this claim on the merits. The Fifth Circuit found that since the Batson claim was meritless, the appellate counsel's failure to raise it was neither unreasonable nor prejudicial, and denied the COA on this claim as well.Ricks argued that his due process rights were violated when the jury saw him in shackles. The district court rejected this claim, noting that Ricks exposed his shackles himself and failed to show any substantial influence on the jury's verdict. The Fifth Circuit found this claim procedurally defaulted because it was not raised on direct appeal and was barred by the Texas Court of Criminal Appeals. Consequently, no COA was issued for this claim.Lastly, Ricks claimed ineffective assistance of trial counsel for not objecting to the shackling and for not challenging the State's peremptory strikes against female venire members. The Fifth Circuit found the trial counsel's decisions reasonable and strategic, and thus denied the COA on these claims.The Fifth Circuit denied the motion for a COA on all claims. View "Ricks v. Lumpkin" on Justia Law

Benjamin Benfer and his wife were pulled over by Officer Barry Calvert for allegedly running a red light and because their vehicle matched the description of a stolen car. A confrontation ensued, during which Calvert used his K-9 to subdue Benfer. Both Benfer and his wife were arrested and charged with resisting arrest and interference with public duties, but the charges were later dismissed.Benfer filed a lawsuit against Calvert and the City of Baytown under 42 U.S.C. § 1983 and state law, claiming violations of his constitutional rights and state tort claims. The United States District Court for the Southern District of Texas dismissed the case, ruling that Calvert did not violate Benfer’s constitutional rights, that Benfer’s state tort claims were not valid under Texas law, and that Benfer did not provide sufficient facts to support his claims against the City under Monell v. Department of Social Services.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that Calvert had reasonable suspicion to stop Benfer, probable cause to arrest him for resisting arrest, and did not use excessive force in deploying his K-9. The court also found that Benfer’s state law assault claim against Calvert was barred by the Texas Tort Claims Act, which requires such claims to be brought against the municipality, not the individual officer. Additionally, the court ruled that Benfer failed to provide sufficient evidence to support his claims against the City of Baytown for inadequate policies, failure to train, and ratification of Calvert’s conduct. View "Benfer v. City of Baytown" on Justia Law

In 2016, the United States Department of Justice (DOJ) sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act (CRIPA), alleging unconstitutional conditions in the County’s detention facilities, particularly the Raymond Detention Center (RDC). The DOJ and the County entered into a consent decree to improve conditions, but disputes over compliance led to the DOJ alleging the County's non-compliance and seeking contempt sanctions. The district court found the County in contempt twice and, after a hearing, issued a new, shorter injunction focused on RDC and appointed a receiver to oversee compliance.The United States District Court for the Southern District of Mississippi found ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, misuse of force, poor incident reporting, and over-detention. The court declined to terminate the consent decree, instead issuing a new injunction and appointing a receiver to manage RDC. The County appealed the new injunction and the receivership.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision to retain most of the injunction’s provisions, finding that the conditions at RDC constituted ongoing constitutional violations. However, the court found that the district court’s need-narrowness-intrusiveness analysis for the receivership was insufficient and that the receiver’s authority over the budget and financial matters was overly broad. The Fifth Circuit reversed the provisions related to the Prison Rape Elimination Act (PREA) and remanded the case for further proceedings to adjust the scope of the receivership and remove the PREA-related provisions. The court affirmed the district court’s decision in all other respects. View "United States v. Hinds County Board of Supervisors" on Justia Law

Marcus McVae was stopped by Texas State Trooper Jesse Perez for a traffic violation. McVae provided a false identity and fled on foot when the officer attempted to detain him. Despite being tased, McVae continued to flee, leading to a physical altercation with Trooper Perez. During the struggle, McVae threw a rock at Perez, who then fatally shot McVae. McVae’s parents sued Perez under 42 U.S.C. § 1983, claiming excessive force in violation of the Fourth Amendment.The United States District Court for the Western District of Texas granted summary judgment in favor of Trooper Perez, finding that he was entitled to qualified immunity. The court relied on body camera footage to support its decision, concluding that no genuine dispute of material fact existed regarding whether McVae posed an immediate threat to Perez.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Trooper Perez’s use of deadly force was reasonable under the circumstances. The court found that McVae’s actions, including throwing a rock at Perez, constituted a severe threat, justifying the use of deadly force. The court concluded that Perez did not violate McVae’s Fourth Amendment rights and was entitled to qualified immunity. View "McVae v. Perez" on Justia Law

A police officer, David Stanley, was suspended and transferred by the Lafayette Police Department (LPD) following an investigation into his Facebook posts. Stanley took sick leave for about a year and appealed his suspension to the Municipal Fire and Police Civil Service Board. He also filed two petitions in state court seeking to enjoin the suspension and transfer. The state district court granted a temporary restraining order (TRO), but the state appellate court dismissed LPD’s appeal of the TRO. Stanley re-filed his petition, but the state district court found he needed to finalize his appeal with the Civil Service Board first. The Civil Service Board later reduced his suspension but upheld his transfer.Stanley then filed a lawsuit in federal district court under 42 U.S.C. § 1983, alleging First Amendment violations and retaliation. The district court dismissed his claims as time-barred, determining that the one-year prescriptive period began when Stanley was notified of his suspension on June 11, 2021. The court also concluded that Stanley’s state court petitions did not interrupt the prescription period because they did not assert federal claims or seek monetary damages.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Stanley’s § 1983 claims accrued when he received notice of the adverse actions, not when the administrative appeal concluded. The court also found that Stanley’s state court petitions did not interrupt the prescription period because they did not provide adequate notice of his federal claims or demand monetary damages. Consequently, the Fifth Circuit affirmed the district court’s dismissal of Stanley’s claims as prescribed. View "Stanley v. Morgan" on Justia Law