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

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation. View "Doe v. Charter Communications" on Justia Law

Tracy Langiano alleged that he was shot and injured by Officer Landon Rollins in violation of the Fourth Amendment and that the City of Fort Worth’s policies contributed to this violation. Langiano was accused of sexually abusing his step-granddaughters and left his home after writing a suicide note. He checked into a motel with a loaded handgun, intending to kill himself. His son informed the police about the suicide note and the handgun. Police located Langiano at the motel, and Officer Rollins, without knocking, entered the room. Rollins claimed Langiano pointed a gun at him, prompting Rollins to shoot Langiano multiple times. Langiano disputed pointing the gun at Rollins but admitted holding it.The United States District Court for the Northern District of Texas denied Langiano’s motion to stay the civil suit while criminal charges were pending. The court granted summary judgment in favor of Officer Rollins and the City of Fort Worth, dismissing Langiano’s civil suit. Langiano appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the stay, as Langiano did not demonstrate substantial and irreparable prejudice. The court also affirmed the summary judgment in favor of Officer Rollins, finding that Rollins’ use of force was reasonable given the circumstances and that Langiano’s Fourth Amendment rights were not violated. Additionally, the court held that the warrantless entry into the motel room was justified due to the exigent circumstances of Langiano being armed and suicidal. The court also affirmed the summary judgment in favor of the City, as there was no constitutional violation to support a Monell claim. The district court’s judgment was affirmed. View "Langiano v. City of Fort Worth" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law

David Wood was convicted of capital murder and sentenced to death in 1992 for the brutal murders of six females in 1987. The victims were found buried near El Paso, and evidence indicated that Wood had sexually assaulted them before killing them. Wood's conviction and sentence were affirmed by the Texas Court of Criminal Appeals (CCA). Over the years, Wood pursued extensive litigation in state and federal courts, including multiple motions for post-conviction DNA testing under Chapter 64 of the Texas Code of Criminal Procedure. The trial court granted some of his motions, but the results did not exonerate him. Subsequent motions were denied, and the CCA affirmed these denials, concluding that Wood had engaged in a pattern of piecemeal litigation and delay.Wood then filed a 42 U.S.C. § 1983 suit in the United States District Court for the Western District of Texas, alleging that the CCA's construction of Chapter 64 violated his procedural due process rights. He claimed that the CCA's consistent denial of DNA testing rendered the state-created testing right illusory and that the CCA's interpretation of the statute's unreasonable-delay provision was novel and unforeseeable. The district court dismissed Wood's complaint and denied his motion to stay his execution.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wood lacked standing for his first claim because a favorable ruling would not substantially likely lead to DNA testing. For his second claim, the court found it meritless, as the CCA's interpretation of the unreasonable-delay provision was neither novel nor unforeseeable. Consequently, the Fifth Circuit affirmed the district court's order and judgment and denied Wood's renewed motion to stay his execution. View "Wood v. Patton" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

In February 2020, Nicolas Robertson was shot and killed in Jackson, Mississippi. Two months later, Samuel Jennings, who was arrested for burglary and grand larceny, provided a statement to Detective Jacquelyn Thomas implicating Desmond Green in the murder. Green was subsequently indicted by a grand jury and detained for nearly two years. In March 2022, Jennings recanted his statement, admitting he was under the influence of drugs when he implicated Green and had no actual knowledge of the murder. Green was released from jail after the charges were dismissed.Green sued Detective Thomas under 42 U.S.C. § 1983, alleging violations of his Fourth and Fourteenth Amendment rights, including malicious prosecution and false arrest without probable cause. The United States District Court for the Southern District of Mississippi denied Detective Thomas qualified immunity at the motion-to-dismiss stage, allowing Green's claims to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Green sufficiently alleged violations of his clearly established Fourth Amendment right against false arrest and his Fourteenth Amendment due process rights. The court found that Detective Thomas allegedly manipulated a photo lineup and withheld exculpatory evidence from the grand jury, which could have influenced the grand jury's decision to indict Green. However, the court granted Detective Thomas qualified immunity on Green's malicious prosecution claim, as the constitutional tort of malicious prosecution was not clearly established in the Fifth Circuit at the time of Green's arrest.The Fifth Circuit affirmed the district court's denial of qualified immunity for Green's false arrest and due process claims but reversed the denial of qualified immunity for the malicious prosecution claim. View "Green v. Thomas" on Justia Law

Annette Rodriguez, the plaintiff, served as the Director of the City of Corpus Christi and Nueces County Public Health District. Her salary was split between the City and the County. In 2019, the City increased her salary to 90% of the market rate. During the COVID-19 pandemic, Rodriguez requested and initially received overtime pay, but the City later stopped these payments. Rodriguez faced several allegations of policy violations and creating a hostile work environment, leading to a disciplinary memorandum. Despite a positive evaluation from the County, the City terminated her in 2022 and hired a new director.Rodriguez sued the City in the United States District Court for the Southern District of Texas, claiming violations under the Equal Pay Act, Fair Labor Standards Act (FLSA), Title VII, and 42 U.S.C. § 1983. The district court dismissed her Section 1983 claim on the pleadings, finding she did not allege a constitutionally protected interest in continued employment. The court granted summary judgment to the City on the remaining claims, concluding Rodriguez was exempt from FLSA overtime pay requirements, did not establish the equal-work or equal-pay prongs of her EPA claim, and failed to identify a proper comparator for her Title VII claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's rulings, agreeing that Rodriguez did not engage in protected activity under the FLSA, failed to identify a proper comparator for her Title VII and EPA claims, and did not establish pretext for retaliation. The court also found that Rodriguez remained an exempt employee despite receiving additional overtime pay temporarily. The court concluded that the City paid Rodriguez on a salary basis, maintaining her exempt status under the FLSA. View "Rodriguez v. City of Corpus Christi" on Justia Law

A neighbor called the Fort Worth Police Department at 2:25 a.m. on October 12, 2019, to report that Atatiana Jefferson's front door was open, which was unusual. Officer Aaron Dean and another officer responded, arriving at 2:28 a.m. and 2:29 a.m., respectively. Following protocol, they parked out of view and did not use emergency lights or sirens. They conducted a perimeter sweep of the house, using flashlights to look for signs of a break-in. Jefferson, who was home with her nephew, noticed someone outside and approached the window. Dean, without announcing himself as an officer, commanded Jefferson to show her hands and then fired a shot, killing her.The United States District Court for the Northern District of Texas denied Dean's motion to dismiss based on qualified immunity and stayed discovery. Dean appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's judgment regarding the excessive force claim, holding that Dean's use of deadly force without warning was objectively unreasonable under clearly established law. However, the court reversed the district court's judgment on the unreasonable search claim, finding that Dean was performing a community caretaking function and that there was no clearly established law indicating his actions were unreasonable. The case was remanded for further proceedings consistent with the opinion. View "Bakutis v. Dean" on Justia Law

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law