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

Plaintiff and others filed a class action against the County under 42 U.S.C. 1983, alleging that the County's system of setting bail for indigent misdemeanor arrestees violated Texas statutory and constitutional law, as well as the equal protection and due process clauses of the Fourteenth Amendment. The district court denied the County's summary judgment motion and granted plaintiff's motion for a preliminary injunction. The Fifth Circuit affirmed most of the district court's rulings, including its conclusion that plaintiff established a likelihood of success on the merits of its claims that the County's policies violated procedural due process and equal protection. However, the court held that the district court's definition of plaintiff's liberty interest under due process was too broad, and the procedures it required to protect that interest were too onerous; the district court erred by concluding that the County Sheriff could be sued under section 1983; and the district court's injunction was overbroad. Therefore, the court dismissed the Sheriff from the suit, vacated the injunction, and ordered the district court to modify its terms. View "ODonnell v. Harris County, Texas" on Justia Law

The Fifth Circuit affirmed the district court's dismissal, for want of Article III standing, plaintiff's claims under the Americans with Disabilities Act (ADA). Plaintiff, a paraplegic, alleged that defendant's parking lot did not have the number of spaces required by the ADA and lacked access ramps. In this case, defendant filed nearly 400 lawsuits in just over 300 days and could not remember a single establishment that he sued and then returned to. Therefore, plaintiff has failed to show any likelihood of future injury necessary to obtain equitable relief; the district court did not abuse its discretion in issuing a contempt order fining counsel $2,500; and the district court did not wrongfully award attorney's fees where the district court only awarded costs. View "Deutsch v. Annis Enterprises, Inc." on Justia Law

The Fifth Circuit affirmed the district court's dismissal, for want of Article III standing, plaintiff's claims under the Americans with Disabilities Act (ADA). Plaintiff, a paraplegic, alleged that defendant's parking lot did not have the number of spaces required by the ADA and lacked access ramps. In this case, defendant filed nearly 400 lawsuits in just over 300 days and could not remember a single establishment that he sued and then returned to. Therefore, plaintiff has failed to show any likelihood of future injury necessary to obtain equitable relief; the district court did not abuse its discretion in issuing a contempt order fining counsel $2,500; and the district court did not wrongfully award attorney's fees where the district court only awarded costs. View "Deutsch v. Annis Enterprises, Inc." on Justia Law

The Fifth Circuit affirmed the district court's grant of unitary status in the area of faculty and staff employment per a consent decree to monitor the school district's efforts to desegregate its school system. The court held that the school district complied with the consent decree in good faith and intervenors failed to show otherwise. The court also agreed with the district court that the school district has eliminated the vestiges of de jure discrimination in employment. View "United States v. Mississippi" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against defendant and others, after plaintiff was charged and then acquitted of murder. In this case, the Fifth Circuit vacated the district court's grant of defendant's motion for summary judgment based on qualified immunity and remanded for trial essentially on the factual issue of whether defendant acted recklessly, knowingly, or intentionally by omitting and misrepresenting material facts in his affidavit when seeking an arrest warrant for plaintiff. The court noted that, considering that fact that this litigation continued for over seven years, the case should go to trial without delay. View "Winfrey, Jr. v. Rogers" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment against plaintiff on her claims of retaliation under Louisiana state law and the First Amendment, deprivation of her liberty and reputational interests under the Fourteenth Amendment, and intentional infliction of emotional distress. The court held that plaintiff did not show that she was subjected to an adverse employment action and her claim under state law failed; plaintiff's claims of municipal liability failed because plaintiff did not identify any official school board policy or custom in accordance with which the allegedly unconstitutional conduct occurred; plaintiff's claims against school officials in their individual capacities failed based on their claims of qualified immunity; plaintiff's Fourteenth Amendment liberty and reputational interests claims failed because the school district never discharged plaintiff; and plaintiff's claim of intentional infliction of emotional distress failed because plaintiff did not demonstrate that any of the defendants' conduct was extreme and outrageous or more than a reasonable person could be expected to endure. View "Rayborn v. Bossier Parish School Board" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment against plaintiff on her claims of retaliation under Louisiana state law and the First Amendment, deprivation of her liberty and reputational interests under the Fourteenth Amendment, and intentional infliction of emotional distress. The court held that plaintiff did not show that she was subjected to an adverse employment action and her claim under state law failed; plaintiff's claims of municipal liability failed because plaintiff did not identify any official school board policy or custom in accordance with which the allegedly unconstitutional conduct occurred; plaintiff's claims against school officials in their individual capacities failed based on their claims of qualified immunity; plaintiff's Fourteenth Amendment liberty and reputational interests claims failed because the school district never discharged plaintiff; and plaintiff's claim of intentional infliction of emotional distress failed because plaintiff did not demonstrate that any of the defendants' conduct was extreme and outrageous or more than a reasonable person could be expected to endure. View "Rayborn v. Bossier Parish School Board" on Justia Law

Plaintiff, a former Austin City Councilmember, filed suit challenging four provisions of Austin's campaign-finance law: a base limit on contributions to candidates; an aggregate limit on contributions from persons outside of the Austin area; a temporal restriction prohibiting all contributions before the six months leading up to an election; and a disgorgement provision requiring candidates to distribute excess campaign funds remaining at the end of an election. The Fifth Circuit affirmed the district court's decision upholding the base limit; holding that plaintiff lacked standing to challenge the aggregate limit because he had not established a sufficient injury-in-fact traceable to that limit; holding that Austin had failed to establish that the six-month temporal limit on fundraising served the interest of preventing actual corruption or its appearance; and holding that plaintiff had standing to challenge the disgorgement provision and the disgorgement provision was unconstitutional. View "Zimmerman v. Austin, Texas" on Justia Law

Plaintiffs, death row inmates housed in cells without air conditioning, filed suit alleging a violation of their Eighth Amendment rights. A panel of the Fifth Circuit held that an Eighth Amendment violation had occurred and that injunctive relief was appropriate but that the district court had exceeded the bounds of the Prison Litigation Reform Act (PLRA) and Gates v. Cook, 376 F.3d 323, 339–40 (5th Cir. 2004), by mandating facility-wide air conditioning and setting a maximum heat index. The Fifth Circuit reversed, holding that the district court erroneously addressed the propriety of a maximum heat index, found that it was necessary, and issued a modified injunction that in certain instances incorporated it. The court remanded for further proceedings. View "Ball v. LeBlanc" on Justia Law

Plaintiffs, death row inmates housed in cells without air conditioning, filed suit alleging a violation of their Eighth Amendment rights. A panel of the Fifth Circuit held that an Eighth Amendment violation had occurred and that injunctive relief was appropriate but that the district court had exceeded the bounds of the Prison Litigation Reform Act (PLRA) and Gates v. Cook, 376 F.3d 323, 339–40 (5th Cir. 2004), by mandating facility-wide air conditioning and setting a maximum heat index. The Fifth Circuit reversed, holding that the district court erroneously addressed the propriety of a maximum heat index, found that it was necessary, and issued a modified injunction that in certain instances incorporated it. The court remanded for further proceedings. View "Ball v. LeBlanc" on Justia Law