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

This case arose when the FDIC filed a complaint against appellants for sums due under various promissory notes. Appellants then entered into a Stipulated Judgment in favor of FDIC and against appellants. CadleRock moved ex parte to re-open the case to allow it to file the necessary pleadings to revive the Stipulated Judgment and the district court granted the motion. CadleRock then filed an ex parte motion to revive the Stipulated Judgment (Revived Judgment) as it pertained to appellants and the district court granted the motion. Five years later, CadleRock commenced collection and served appellants with pleadings and appellants moved to vacate and annul. At issue on appeal was the district court's order denying appellants' Federal Rule of Civil Procedure 60(b)(4) motion to vacate. The court concluded that the Revived Judgment was not void under Rule 60(b)(4); appellants' due process challenges failed; and, given that appellants have not shown an actual conflict between federal and state law, their preemption claim failed. Accordingly, the court affirmed the district court's judgment. View "FDIC v. SLE, Inc., et al." on Justia Law

Plaintiff appealed the termination of her Medicaid benefits. At issue was the enforceability of a provision of the Medicaid Act, 42 U.S.C. 1396a(a)(8), under 42 U.S.C. 1983. The court concluded that section 1396a(a)(8) created a right enforceable under section 1983, and that exhaustion of Louisiana's procedure for judicial review was not required before a Medicaid claimant filed suit in federal court. Accordingly, the court affirmed the judgment of the district court denying DHH's motion to dismiss because plaintiff's claims were properly before the district court. View "Romano v. Greenstein" on Justia Law

Plaintiff, as next-friend to her minor daughter, brought suit under 42 U.S.C. 1983 against high school softball coaches, alleging that the coaches disclosed the daughter's sexual orientation during a disciplinary meeting with plaintiff, primarily claiming the disclosure to plaintiff constituted a Fourteenth Amendment invasion of the daughter's privacy. The court held that there was no clearly established law holding that a student in a public secondary school had a privacy right under the Fourteenth Amendment that precluded school officials from discussing with a parent the student's private matters, including matters relating to the sexual activity of the student. The court also held that such students have no clearly established Fourteenth Amendment right that barred a student-coach confrontation in a closed and locked room. Therefore, the court concluded that the coaches were entitled to qualified immunity that barred the federal claims against them. Accordingly, the court reversed and vacated in part and remanded for entry of judgment dismissing the federal claims against the coaches. View "Wyatt v. Fletcher, et al." on Justia Law

Plaintiff appealed from the district court's dismissal of her claim of sexual harassment under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The district court ruled that plaintiff, a volunteer firefighter, was not an "employee" within the meaning of Title VII. The court concluded that plaintiff was not an "employee" for purposes of Title VII because she failed to make a threshold showing of remuneration. Plaintiff's benefits were purely incidental to her volunteer services with District 5. Accordingly, the court affirmed the district court's judgment. View "Juino v. Livingston Parish Fire District No. 5" on Justia Law

The EEOC sued Houston Funding, alleging that Houston Funding unlawfully discharged one of its employees because she was lactating and wanted to express milk at work. The district court granted summary judgment in favor of Houston Funding, finding that, as a matter of law, discharging a female employee because she was lactating or expressing milk did not constitute sex discrimination. However, given the court's precedent, the court held that the EEOC's argument that Houston Funding discharged the employee because she was lactating or expressing milk stated a cognizable sex discrimination claim under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. An adverse employment action motivated by these factors clearly imposed upon women a burden that male employees need not - indeed, could not - suffer. Moreover, the court held that lactation was a related medical condition of pregnancy for purposes of the Pregnancy Discrimination Act, 42 U.S.C. 2000e-(k). Accordingly, the court vacated and remanded for further proceedings. View "EEOC v. Houston Funding II, et al." on Justia Law

Plaintiffs filed a civil rights action against defendants seeking damages for injuries suffered as a result of their nine-month imprisonment. Plaintiffs were arrested for murder and the charges against them were eventually dropped. On appeal, plaintiffs challenged the district court's grant of summary judgment on the false arrest claim in favor of Defendants Brooks and McNeal, the grant of summary judgment on the malicious prosecution claim in favor of Brooks, and the denial of their motion for leave to amend. Because the district court did not certify as a final judgment its initial order dismissing the claims against Lamar County with prejudice, Lamar County was still a party to the suit at the time plaintiffs sought leave to amend their complaint. The district court thus abused its discretion in denying plaintiffs' motion for leave to amend. The district court did not, however, abuse its discretion when it denied plaintiffs leave to amend their complaint to add Defendant Keele to the litigation. Finally, the court affirmed the district court's orders granting summary judgment to defendants. View "Crostley, et al. v. Lamar County, TX, et al." on Justia Law

Plaintiff, currently serving life sentences in Louisiana, repeatedly sought to have his sentences commuted in order to become eligible for parole. After he was first convicted, Louisiana altered its commutation process. This appeal concerned plaintiff's complaint that the application of the new process to him violated the ex post facto provisions of the United States and Louisiana Constitutions. Because the ultimate decision of the Louisiana governor as to whether to grant or deny commutation remained entirely discretionary, plaintiff could not establish an ex post facto violation by identifying alterations to the State's commutation procedure increasing the amount of time between when commutation applications could be filed and granting the Board authority to deny a full hearing on an applicant. Accordingly, the court affirmed the judgment of the district court. View "Howard v. Blanco, et al" on Justia Law

Plaintiff brought this gender discrimination suit against LSU, alleging that the LSU Police Department violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, et seq., as well as Louisiana state employment law, La. Rev. Stat. Ann. 23:332(A)(1), 23:967, by failing to promote her to the position of Chief of Police and retaliating against her for filing complaints with the EEOC and LCHR. The court reversed the district court's grant of summary judgment in favor of LSU because plaintiff had established a prima facie case of discrimination and there was a genuine disputed issue of fact of whether LSU's alleged non-discriminatory reason for not promoting plaintiff was pretextual. Accordingly, summary judgment on the gender discrimination claim was improper. Plaintiff had also shown a conflict in substantial evidence regarding retaliation and, therefore, summary judgment was improper on that second claim. View "Haire v. Board of Supervisors of LA State University" on Justia Law

This case presented a constitutional challenge to Texas's statutory scheme, which does not allow 18- to 20-year-old adults to carry handguns in public. The court held that the state scheme withstood this challenge because the court was bound by a prior panel opinion of this court, NRA v. Bureau of Alcohol, Tobacco, Firearms, & Explosives. Because plaintiffs Jennings and Harmon were now 21, the court remanded their claims to the district court with instructions to dismiss them as moot. The court also reversed the district court's ruling that the remaining plaintiffs did not have standing to challenge Texas's general criminal provision barring persons from carrying handguns in public. Finally, with respect to the general criminal provision, the court rendered, and with respect to the licensing law the court affirmed the district court, holding that the Texas scheme did not violate the Second or the Equal Protection Clause. View "Nat'l Rifle Ass'n of America Inc, et al. v. McCraw" on Justia Law

Plaintiff brought suit against defendant, a deputy officer, following an altercation between the parties where plaintiff alleged claims of false arrest and excessive force. On appeal, defendant challenged the district court's denial of summary judgment based on qualified immunity on plaintiff's 42 U.S.C. 1983 claims and state-law official immunity on plaintiff's state-law claims. The court held that defendant was entitled to qualified immunity on plaintiff's false arrest claim because a reasonable officer at the scene would have thought that he had probable cause to arrest plaintiff, but not on plaintiff's excessive force claim. In addition, defendant was entitled to official immunity on plaintiff's state-law false arrest and imprisonment claim but not on plaintiff's state-law assault and battery claim. Accordingly, the court reversed in part and dismissed in part. View "Ramirez v. Martinez" on Justia Law