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

In February 2019, Daryl Davis was stopped by Tyler Police Department officers as part of a drug sting. During the traffic stop, officers accused Davis of swallowing crack cocaine to destroy evidence, used force against him, and arrested him for tampering with evidence and interfering with public duties. Davis contended that the stop was pretextual, that he was falsely accused, subjected to excessive force, unlawfully detained, and that officers refused to order a drug test that would have disproven their accusation. He further alleged ongoing constitutional violations following his arrest, including malicious prosecution and unlawful searches and seizures during pretrial supervision, and claimed that city and county officials ignored his complaints to cover up broader unconstitutional policing.A magistrate judge in the United States District Court for the Eastern District of Texas screened Davis’s pro se complaint, found it untimely and lacking in sufficient factual allegations, and ordered him to amend. After Davis amended, the magistrate judge recommended dismissal for failure to state a claim, finding the claims time-barred under Texas’s two-year statute of limitations for § 1983 actions and insufficiently specific as to officials’ failure to act. The district court adopted this recommendation, dismissing the claims without prejudice except for those based on officials’ inaction, which were dismissed with prejudice. Davis appealed.The United States Court of Appeals for the Fifth Circuit affirmed the dismissal of Davis’s unlawful arrest, excessive force, and malicious prosecution claims, concluding they were time-barred or failed as a matter of law. The court also agreed that Davis had not sufficiently pleaded claims based on officials’ failure to act, but held those should have been dismissed without prejudice. The court vacated that portion of the judgment and remanded, directing the district court to allow Davis to amend his complaint and consider appointing counsel. The court expressed no opinion on the merits of any future pleadings. View "Davis v. Warren" on Justia Law

The case concerns a search of Albert Alexander’s residence by Lafayette Police Department officers, who had a warrant to search for firearms. Upon executing the warrant, the officers found only pellet rifles, but also observed a large quantity of electronics and appliances—many in unopened boxes or wrapped—inside the house. These observations, combined with prior tips from Alexander’s granddaughter and her girlfriend that stolen goods were stored there, led the officers to seize the items on suspicion they were stolen. The seized property was not listed in the original search warrant.After being charged with possession of stolen property and later acquitted at trial, Alexander filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Louisiana. He alleged that the officers violated his Fourth Amendment rights by seizing items not listed in the warrant during the first search. The defendants moved for summary judgment, asserting qualified immunity. The district court granted summary judgment, finding that the officers’ seizure of the electronics and appliances was justified under the plain view doctrine, as their incriminating nature was immediately apparent given the circumstances and information available to the officers.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the officers did not violate the Fourth Amendment because, under the totality of the circumstances—including the tips received, officers’ observations, and their experience—the officers had probable cause to believe the items were stolen, satisfying the plain view exception. The court affirmed the district court’s grant of summary judgment, holding that the officers were entitled to qualified immunity. View "Alexander v. Arceneaux" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded for the district court to decide whether the right was clearly established.On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established. The officers appealed. The United States Court of Appeals for the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Thus, Coborn was not entitled to qualified immunity for the second round of shots. View "Baker v. Coborn" on Justia Law

A woman who was pregnant while detained at the Tarrant County Jail gave birth in her cell two weeks before her due date. The infant was found stuck in her pants and was transported to the hospital, where the child died ten days later. The Medical Director at the jail, a physician who did not provide direct care to inmates in the female infirmary, had issued orders for the treatment of pregnant inmates but relied on other medical staff to carry out those orders. Days before the birth, the woman was seen by an OB/GYN, who noted her communication difficulties and recommended an elective induction of labor at 39–40 weeks, which the Medical Director approved. On the day of the birth, the woman was mentioned in the attachment to a nursing report email regarding abdominal cramps and refusal of breakfast, but not in the body of the email. The Medical Director stated he did not read the attachment before learning the birth had occurred.After the incident, the woman, through her guardian, filed suit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Texas, alleging the Medical Director denied her adequate medical care in violation of the Fourteenth Amendment. Following discovery, the Medical Director moved for summary judgment, asserting qualified immunity and arguing he lacked subjective knowledge of a substantial risk of serious harm. The district court granted summary judgment for the Medical Director and denied the plaintiff’s cross-motion.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court held that the Medical Director did not have subjective knowledge of a substantial risk of serious harm to the detainee and therefore did not act with deliberate indifference. The court affirmed the district court’s summary judgment in favor of the Medical Director. View "Congious v. Shaw" on Justia Law

A group of former student-athletes filed suit against a university, alleging that between 2012 and 2015, they sustained serious hip injuries while participating on the university's women's rowing team. They claimed that the injuries were caused by deficient coaching, athletic training, and medical care, which they argued were influenced by systemic gender-based disparities. The athletes pursued claims under Title IX for gender discrimination and under Texas law for negligence. The university moved for summary judgment, arguing that the claims were barred by the applicable two-year statute of limitations.The United States District Court for the Northern District of Texas agreed with the university as to eight plaintiffs, granting summary judgment and finding their claims time-barred. For a ninth plaintiff, the district court partially granted and partially denied summary judgment, allowing some claims for compensatory damages to proceed. The plaintiffs appealed the ruling for the eight time-barred claims, and the United States Court of Appeals for the Fifth Circuit affirmed, holding that the claims were indeed barred by the statute of limitations.Following summary judgment, the university sought to recover litigation costs as the prevailing party under Rule 54(d) of the Federal Rules of Civil Procedure and 28 U.S.C. § 1920. The district court found the university to be a prevailing party and awarded the majority of the costs requested, after reducing the amount. The plaintiffs appealed the cost award. The United States Court of Appeals for the Fifth Circuit held that the university was properly designated the prevailing party, that none of the factors in Pacheco v. Mineta weighed against awarding costs, and that the university had met its burden to show the necessity and amount of costs sought. The Fifth Circuit affirmed the district court’s award of costs. View "Clouse v. Southern Methodist University" on Justia Law

The plaintiff owned a building in Corpus Christi, Texas, with significant cultural and historical importance, particularly within the Black community. Over several years, the City’s Code Enforcement Division cited the property for structural deficiencies and ultimately recommended its demolition. Despite the plaintiff’s efforts to preserve the building for historic purposes, the Building Standards Board voted to recommend demolition at a hearing that the plaintiff and her counsel could not attend. After the City temporarily suspended the demolition order, it imposed conditions on the plaintiff to secure the property, which the City later deemed unmet. The City then gave the plaintiff 30 days to demolish the building or face further action.The plaintiff filed suit in Texas state court against the City and two City employees, alleging that selective enforcement of building codes violated her rights under the Equal Protection Clause, asserting a “class of one” theory under 42 U.S.C. § 1983. The case was removed to the United States District Court for the Southern District of Texas. The district court dismissed the complaint for failure to state a claim, finding that the plaintiff had not sufficiently pleaded a substantive constitutional violation and thus did not reach the question of municipal liability.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed only the claim against the City, as the plaintiff did not pursue claims against the individual defendants. The Fifth Circuit affirmed the dismissal. The court held that the plaintiff’s allegations did not establish a municipal policy, custom, or pattern of selective enforcement sufficient to state a claim for municipal liability under Monell v. Department of Social Services. The court found that a single cited instance of allegedly selective enforcement was insufficient to plead an official policy or custom. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the action. View "Cambric v. City of Corpus Christi" on Justia Law

A federal law enforcement officer was charged following two separate incidents that took place at a U.S. border crossing. In the first, the officer confronted an individual, Espinosa, who had been involved in a verbal disagreement with another officer. The officer intervened, physically redirected Espinosa, and both collided with a door, resulting in Espinosa experiencing physical injuries such as dizziness and confusion. Testimony from a supervisor and an expert witness indicated the force used was excessive and not justified by Espinosa’s behavior at the time. In the second incident, the officer engaged with Estrada, a returning traveler, following a verbal exchange. The officer brought Estrada into a secure area, used force to restrain him, and pressed his face into chairs, causing a nose injury. Witnesses and expert testimony again described the officer’s actions as excessive and unnecessary, and video evidence did not show Estrada acting aggressively or resisting.After these events, the officer filed a report about the Estrada incident, which contained statements that were contradicted by video evidence and expert analysis. The officer also made verbal statements to a supervisor that were later found to be false.The United States District Court for the Western District of Texas conducted a bench trial, found the officer guilty of two counts of deprivation of rights under color of law (18 U.S.C. § 242) and one count of falsifying a record in a federal investigation (18 U.S.C. § 1519), and imposed concurrent sentences below the guidelines. The officer appealed, challenging the sufficiency of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a highly deferential standard to the verdict. The court held that a rational factfinder could find all elements of the crimes proven beyond a reasonable doubt and affirmed the convictions. View "United States v. Delgado" on Justia Law

Michael Hickson, who had become severely disabled following cardiac arrest and anoxic brain injury in 2017, was hospitalized multiple times for recurring infections but recovered from several serious episodes. In June 2020, while hospitalized for pneumonia, sepsis, and suspected COVID-19, his doctors at St. David’s Healthcare assessed him as having a 70% chance of survival. Despite this, he was placed on hospice care and a do-not-resuscitate order was issued, with medical staff indicating that his inability to walk or talk equated to a poor quality of life. Life-sustaining treatment, including food and fluids, was withdrawn, even as his condition temporarily improved. Michael’s family, led by his wife Melissa Hickson, sought answers and attempted to visit him, but were repeatedly denied access and information. Michael ultimately passed away, and subsequent public statements by the hospital disclosed protected health information and cast aspersions on Melissa’s fitness as a guardian.The United States District Court for the Western District of Texas dismissed or granted summary judgment in favor of the defendants on all claims, including disability discrimination under § 504 of the Rehabilitation Act and § 1557 of the ACA, § 1983 claims, state-law medical negligence, informed consent, wrongful death, and intentional infliction of emotional distress. The plaintiffs objected to the recommendations for dismissal of the disability discrimination and § 1983 claims; the district court overruled these objections and dismissed those claims with prejudice. The remaining state-law claims were later resolved on summary judgment.Upon de novo review, the United States Court of Appeals for the Fifth Circuit held that disability discrimination claims based on alleged denial of medical treatment solely due to disability are cognizable and may proceed. The court also vacated and remanded the dismissals of the informed consent and intentional infliction of emotional distress claims, but affirmed dismissal of the § 1983 claims and other state-law claims. View "Hickson v. St. David's Healthcare Partnership" on Justia Law

A school administrator responsible for special education at a high school in Texas alleged that his employment was terminated in retaliation for reporting incidents of child abuse by teachers under his supervision and for cooperating with a subsequent Child Protective Services (CPS) investigation. He reported the incidents to his principal, participated in a CPS interview, and raised concerns about disciplinary actions and workplace conduct. After additional workplace conflicts and an EEOC complaint, his contract was ultimately terminated by the district’s Board of Trustees following a hearing, and his administrative appeal was unsuccessful.The United States District Court for the Eastern District of Texas reviewed the administrator’s claims, which included constitutional violations under the First and Fourteenth Amendments, retaliation for whistleblowing, and a civil conspiracy to violate his rights. The district court granted the defendants’ motions to dismiss for failure to state a claim, denied leave to amend the complaint, and denied a motion to alter or amend the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the administrator’s speech—reporting child abuse to his supervisor, participating in the CPS investigation, and refusing to characterize events as his supervisor wished—was made in his official capacity as an employee, not as a citizen, and was therefore not protected by the First Amendment. The court also found that he received appropriate procedural due process related to his termination and did not state a claim for substantive due process. The individual defendants were entitled to qualified immunity, and the civil conspiracy claim failed because there was no underlying constitutional violation. The court also concluded that the district court did not abuse its discretion in declining to take judicial notice of the administrative record and found other claims waived. View "Castille v. Port Arthur Independent School District" on Justia Law