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

Plaintiff appealed the district court's sua sponte dismissal of his civil rights complaint as frivolous and for failure to state a claim upon which relief could be granted. The court held that the district court abused its discretion in dismissing the claim against one corrections officer at the initial screening stage and before the filing of any responsive pleadings. The district court did not err in dismissing plaintiff's denial of medical care claim where the officers did not show deliberate indifference regarding plaintiff's denial of medical treatment and because the officers took plaintiff to see a V.A. hospital physician after the incident at issue and transported him subsequently to the prison medical department for treatment. In regards to the claim regarding plaintiff's injury in the van, the issue was moot. As for the denial of medical care claim, allowing plaintiff to amend his complaint would have been futile and the district court did not err in declining to provide leave to file an amended complaint. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Rogers v. Boatright, et al" on Justia Law

Defendant was found not guilty of second degree murder by reason of insanity and was committed to the Attorney General's custody under 18 U.S.C. 4243(e). Defendant was subsequently found to no longer be a substantial risk to others if he followed a strict treatment regimen and was conditionally released. The district court then later found that defendant failed to comply with the conditions of his release and that he posed a substantial risk of bodily injury to others. Consequently, the district court revoked the release and placed him back into the custody of the Attorney General. The court held that the district court did not abuse its discretion in not calling for a competency hearing; defendant failed to raise a valid Sixth Amendment complaint and the district court did not abuse its discretion in refusing to replace counsel; and the district court committed no error in its finding underlying the conclusion to revoke the conditional release. Accordingly, the court affirmed the order. View "United States v. Mitchell" on Justia Law

Defendants Mathew Dean Moore and Melvin Williams, former New Orleans Police Officers (NOPD), appealed their convictions and sentences arising from an incident that resulted in the death of an individual. The court concluded that a jury could reasonably conclude from the evidence that the individual's death was proximately caused by and the foreseeable result of being kicked in the chest by Williams; the district court did not err by basing Williams' sentence on the base offense of voluntary manslaughter; the evidence was sufficient to sustain Moore's conviction for aiding and abetting the submission of a false incident report and by obstructing a federal investigation through the submission of a false NOPD incident report and aiding and abetting each other; the evidence was sufficient to sustain Moore's conviction for making false, material statements to the FBI; and the district court did not err in determining Moore's sentence. Accordingly, the court affirmed the convictions and sentences. View "United States v. Moore, et al" on Justia Law

Plaintiff, a former TDCJ employee, appealed the district court's grant of summary judgment for TDCJ on her Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a)(1)(D), claims. Plaintiff's allergic reaction to the use of scented candles and wall plug-ins around her work area was the basis of her ADA claim. The court held that plaintiff did not suffer from a disability within the meaning and coverage of the ADA. Further, there was no dispute that TDCJ did not receive plaintiff's FMLA certification before the deadline. Accordingly, the court affirmed the judgment. View "Milton v. Texas Dept. of Criminal Justice" on Justia Law

Mariner's Cove Townhomes Association appealed the district court's grant of summary judgment on the pleadings for the United States. The district court held that the Association was not entitled to just compensation for the diminution of its assessment base resulting from the government's condemnation of fourteen properties in the Mariner's Cove Development. The court found that the Association's right to collect assessments was a property interest, but the loss of the Association's assessment base was incidental to the condemnation and was barred by the consequential loss rule. Accordingly, the court held that the loss of the Association's right to collect assessments on those properties was not compensable under the Takings Clause of the Fifth Amendment. View "United States v. Land" on Justia Law

Plaintiff sued the school district alleging that the district's decision to hire a Caucasian woman in lieu of promoting him amounted to race discrimination in violation of Title VII. The district court granted summary judgment to the district and ordered plaintiff to pay attorneys' fees. The court found no competent evidence from which a reasonable juror could infer that the district's decision to hire the woman in lieu of promoting plaintiff was motivated by impermissible racial considerations. The court held, however, that the district court's fee award constituted an abuse of discretion where the court did not agree that plaintiff's claim was frivolous, unreasonable, or without foundation. View "Autry v. Fort Bend Independent Sch. Dist." on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the school district, alleging that she was denied a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that plaintiff satisfied the court's liberal notice of appeal requirements and therefore considered the appeal on the merits. The court found that the district court complied with the IDEA's procedural requirements and, moreover, if any defects existed, they did not rise to the level of denying plaintiff a lost educational opportunity. In regards to plaintiff's substantive claim, the court analyzed the Michael F. factors and concluded that plaintiff received a FAPE. Accordingly, the court affirmed the judgment. View "R. P. v. Alamo Heights Indep Sch Dist" on Justia Law

Defendants appealed the denial of their motion for summary judgment based on qualified immunity from plaintiff's 42 U.S.C. 1983 excessive-force and state-law claims. The district court denied summary judgment, concluding that there were issues of material fact as to whether the force used by the officers was clearly excessive and objectively unreasonable. Under the applicable law, the court had no jurisdiction to review a district court's determination that there were genuine disputes of fact where the court had decided, as a matter of law, that those factual issues were material. Therefore, the court affirmed the judgment of the district court and dismissed the appeal. View "Newman v. Guedry, et al" on Justia Law

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