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

Plaintiff filed suit alleging race discrimination when defendant terminated his contract. Plaintiff, who was white, served as the attorney for defendant for 24 years and was subsequently replaced by a black women as defendant's attorney. At issue was whether the district court properly granted judgment as a matter of law under Federal Rule of Civil Procedure 50. The court held that plaintiff did not meet his burden of presenting legally-sufficient evidence on which the jury could conclude that defendant intentionally discriminated against him on his race and therefore, the district court properly granted summary judgment to defendant under Rule 50(a)(1). The court also rejected plaintiff's claim that he had superior qualifications than the new attorney and plaintiff's argument that the district court erred by refusing to admit a certain article under Federal Rules of Evidence 801(c) and 802.

Plaintiff sued her former employer, University Healthcare System, L.C. (UHS), for sex discrimination, retaliation, breach of oral contract, violation of the Equal Pay Act (EPA), 29 U.S.C. 206(d), and violation of the Louisiana Wage Payment Statute (LWPS), La. Rev. Stat. Ann 23:631. Both parties raised challenges on appeal relating to either the admission or discoverability of evidence. The court reversed the district court's award in favor of plaintiff under the LWPS and vacated the judgment as to that claim where there was no evidence of any completed oral contract to pay plaintiff the bonus and the jury's conclusion that such an obligation existed could not be justified based on the record. The court also reversed the award of attorney's fees related to the LWPS claim to plaintiff and vacated the judgment as to the amount of fees rewarded. The court further held that, in all other respects, the judgment of the district court was affirmed. The court remanded to the district court for a determination of the amount of attorney's fees attributable to plaintiff's EPA claim. Plaintiff's trial counsel's motion for leave to assert privilege for attorneys' fees and costs on judgment was denied without prejudice to asserting the rights claimed therein by other means.

Appellant and his wife sued Halliburton Company ("KBR"), alleging claims of sexual harassment and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, assault and battery, intentional infliction of emotional distress, negligence, false imprisonment, and loss of consortium where the claims stemmed from the wife's work in Iraq as a civilian contractor for KBR. At issue was whether the district court erred by concluding that appellant could not, as a matter of law, maintain a loss of consortium claim because the claim arose from a civil rights violation against his wife. The court held that, under Texas law, a loss of consortium claim was derivative of the tortfeasor's liability to the physically injured person. Therefore, where appellant's loss of consortium claim derived solely from his wife's civil rights claim, his right to recover under Title VII could not be supported by his loss of consortium claim. Accordingly, the court affirmed the judgment of the district court.

The Elijah Group, Inc. ("Church") sued the City of Leon Valley ("City") alleging that the City's prohibition of the Church from performing religious services on certain properties violated Texas state law, the federal Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc(b)(1), and both the Texas and U.S. Constitutions. At issue was whether the district court properly dismissed the Church's claims under the Equal Terms Clause of the RLUIPA. The court held that the City's imposition of its land use regulation violated the Equal Terms Clause where the ordinance treated the Church on terms that were less than equal to the terms on which it treated similarly situated nonreligious institutions. Accordingly, the district court's order granting the City's motion for summary judgment was reversed and the case was remanded for further proceedings.

Appellant, proceeding pro se and in forma pauperis, filed a lawsuit against appellees asserting claims under 42 U.S.C. 1983 and Title II of the Americans with Disabilities Act of 1990 ("ADA"), 28 U.S.C. 1915(e)(2), based in part on the allegations that he suffered from certain conditions during his incarceration and appellees failed to provide him with adequate medical care and prevented him from using the community work centers, accessing the satellite and regional prison facilities, working in the kitchen, and attending school. At issue was whether appellees were entitled to sovereign immunity for claims that they violated Title II of the ADA. As a preliminary issue, the court held that appellant had not alleged facts from which the court could reasonably infer that he suffered from a qualifying disability under the ADA and remanded the case to the district court in order to allow appellant to amend his Title II allegations where he had not had an opportunity to amend his claim after being alerted of its deficiencies.

Plaintiff filed an original petition in Texas state court alleging violations of federal law under 42 U.S.C. 1983 and 1985, violations of Texas state law under the Texas whistleblower statute, and common law defamation. At issue was whether the district court abused its discretion by failing to remand the case to Texas state court after all federal claims had been deleted and only Texas state law claims remained. The court held that the district court abused its discretion when it denied plaintiff's motion to remand where the balance of the statutory and common law factors weighed heavily in favor of remanding the pendent Texas state law claims and where Carnegie Univ. v. Cohill did not permit the court to turn any allegation of improper forum manipulation into a trump card which could defeat the heavy balance of the other relevant considerations. Therefore, the court vacated the district court's grant of summary judgment in favor of defendant on each Texas state law claim, reversed the district court's denial of plaintiff's motion to remand, and remanded the case with instructions to the district court to remand the Texas state law claims to the Texas state court from which the case was removed.

Plaintiffs, employers at a terminal for a trucking company, brought claims of race discrimination, retaliation, and hostile work environment against defendant, their employer. At issue was whether the district court properly granted summary judgment in favor of defendants and dismissed each of plaintiff's claims. The court held that summary judgment was proper where the chief district judge's opinion granting summary judgment was thorough and well-reasoned, based on evidence that plaintiffs properly presented and where the district court had no duty to "comb the entire record" for evidence.

Defendants, a husband and wife, filed a suit in federal court alleging that the U.S. Attorney for the Southern District of Mississippi ("U.S. Attorney"), who prosecuted defendants for fraud, bribery, and tax evasion charges, violated 42 U.S.C. 1983 and statutes prohibiting government officials from releasing private tax records obtained in the course of their duties when he included defendants' federal tax records obtained during a criminal investigation in the complaint he filed with the Mississippi Commission on Judicial Performance about the husband's conduct. At issue was whether prosecutorial immunity extended to a prosecutor's post-trial transfer of private federal tax records to a state ethics commission. The court held that the U.S. Attorney did not have prosecutorial immunity in this case where there was no case precedent extending immunity to post-trial conduct relating to a new action before a new tribunal and where the policies underlying prosecutorial immunity did not justify immunity in this context.