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

This case arose from the death of Jason Ray Brown in the Wichita County Jail while he was a pretrial detainee. Plaintiffs appealed the district court's grant of summary judgment to Wichita County and Dr. Daniel Bolin, the physician in charge of the jail, on plaintiffs' federal civil rights claims. The court held that the district court properly analyzed this case as an episodic acts case. The court also held that the district court did not err in granting summary judgment for Dr. Bolin and Wichita County on the issue of qualified immunity. The record contained no evidence of failure of the system of medical care at the Wichita County Jail that would indicate that the the county or the doctor were deliberately indifferent in maintaining that policy. View "Brown, et al v. Wichita County" on Justia Law

Plaintiff filed a complaint, and several amended complaints, against the Louisiana Department of Corrections, asserting that threats and harassment had occurred periodically since July 2006; that he had suffered an excessive use of force in July 2006 and on November 11, 2009; that he had suffered a denial of medical care, a due process denial resulting from an extended stay in lockdown; and state law assault and battery. Because the court found that pre-filing administrative exhaustion was required pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a), the court reversed the district court's denial of defendants' motion for summary judgment and remanded for entry of judgment dismissing the complaint. View "Gonzalez v. Seal, et al" on Justia Law

Defendants contested a summary judgment holding that the Mississippi Caller ID Anti-Spoofing Act (ASA), Miss. Code Ann. 77-3-805, violated the Commerce Clause. Plaintiffs provide nationwide third-party spoofing services to individuals and entities. In light of the carefully-drafted language in section 227(e)(1) of the Truth in Caller ID Act of 2009 (TCIA), 47 U.S.C. 227(e)(1), and legislative history, and in spite of the presumption against preemption that attached to a state's exercise of its police power, there was an inherent federal objective in the TCIA to protect non-harmful spoofing. The ASA's proscription of non-harmful spoofing frustrated this federal objective and was, therefore, conflict preempted. Accordingly, the court affirmed the judgment of the district court. View "Teltech Systems, Inc., et al v. Bryant, et al" on Justia Law

Plaintiff filed a Title VII discrimination suit against his employer, the Department of Homeland Security. At issue on appeal was whether the parties had reached an enforceable settlement. The court concluded that the district court did not abuse its discretion by finding that plaintiff was bound by the terms of his attorney's settlement offer. Further, the court never held that the Fifth Amendment's due process guarantee was implicated by defective representation in Title VII proceedings and plaintiff had introduced no evidence to suggest that his attorney's representation was less than competent. View "Quesada v. Napolitano" on Justia Law

Plaintiff appealed the district court's grant of summary judgment on his age-discrimination claims under Tex. Lab. Code Ann. 21. After defendant investigated the allegation that plaintiff falsified his work and determined that he had, defendant terminated his employment. Because plaintiff failed to present a genuine issue of material fact that his age was a motivating factor in his termination or that defendant created a hostile work environment, the court affirmed the judgment. View "Reed v. Neopost USA, Inc." on Justia Law

The DWC issued a cease and desist letter to plaintiff arguing that his use of the words "Texas" and "Workers' Comp" in the domain name of his website violated section 419.002 of the Texas Labor Code. Plaintiff filed a complaint alleging that the statute was unconstitutional under the First, Fifth, and Fourteenth Amendments. The court affirmed the district court's dismissal of plaintiff's Fifth and Fourteenth Amendment claims. The court also affirmed the district court's ruling that the regulation at issue was content-neutral and did not amount to a prior restraint. The court reversed the district court's finding that the law was constitutional as applied to plaintiff, and remanded to permit the parties to more fully develop the record on this issue. View "Gibson v. Texas Dept. of Ins., et al" on Justia Law

This appeal concerned the constitutionality of 18 U.S.C. 922(b)(1) and (c)(1), and attendant regulations, which prohibited federally licensed firearms dealers from selling handguns to persons under the age of 21. The court held that plaintiffs had standing; the challenged federal laws passed constitutional muster even if they implicated the Second Amendment guarantee; and under intermediate scrutiny, the challenged laws were constitutional under the Second Amendment. The court also rejected plaintiffs' contention that the ban violated the equal protection component of the Fifth Amendment where plaintiffs failed to show that Congress irrationally imposed age qualifications on commercial arms sales. Accordingly, the court affirmed the judgment. View "National Rifle Association, et al v. Bureau of Alcohol, Tobacco, et al" on Justia Law

Plaintiff brought suit against the church alleging that the church terminated him in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court dismissed the suit based on the ministerial exception, which barred employment-discrimination suits by ministers against their churches, pursuant to Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC. Because the court concluded that there was no genuine issue of material fact that the ministerial exception applied where plaintiff performed an important function during the church service as an accompanist, and therefore barred plaintiff's suit, the court affirmed the judgment of the district court. View "Cannata v. Catholic Diocese of Austin, et al" on Justia Law

The Church filed suit in federal district court, claiming that a now-repealed city ordinance's church-specific provisions, facially and as applied, violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., the First Amendment; the Fourteenth Amendment, and the Mississippi Constitution. The Church simultaneously filed a motion for a preliminary injunction of the challenged provisions. The court subsequently vacated the district court's order denying the Church's motion for a preliminary injunction and remanded for further proceedings. The court concluded that the issues on remand included but were not limited to: (1) whether the Church was likely to succeed on its claims challenging the validity of the newly adopted religious facilities ban; (2) whether the harm the Church would suffer absent a preliminary injunction outweighed the harm an injunction would cause the city; (3) the amount of actual damages the Church suffered on account of Sections 10.86 and 10.89 of the city's zoning ordinance, which violated RLUIPA; and (4) at the district court's discretion, whether the Church should be awarded reasonable attorneys fees as a prevailing party under 42 U.S.C. 1988(b). View "Opulent Life Church, et al v. City of Holly Springs MS, et al" on Justia Law

Plaintiff brought a Title VII sex discrimination claim against her former employer. The district court granted summary judgment for the employer on the ground that the grievance procedure established in a collective bargaining agreement (CBA) provided the exclusive remedy for plaintiff's claim. Because the CBA did not clearly and unmistakably waive a union member's right to bring a Title VII claim in a federal judicial forum, the district court erred when it concluded that the CBA required plaintiff to submit her Title VII claim to the Article 51 grievance process. Accordingly, the court vacated the district court's grant of summary judgment for the employer and remanded for further proceedings. View "Ibarra v. United Parcel Service, Inc." on Justia Law