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

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

The Fifth Circuit vacated the magistrate judge's denial of a preliminary injunction after plaintiff filed suit alleging that prison officials exhibited deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Plaintiff, a diabetic, specifically alleged that prison officials cancelled his prescribed diet on multiple occasions, forcing him to consume high-sugar meals up to four times a day, contrary to the orders of his unit physician. Construing plaintiff's pro se pleadings liberally, the court held that plaintiff had alleged a pattern of knowing interferences with prescribed medical care for his diabetes, despite his multiple complaints and his official grievance, which were all essentially ignored. Such allegations were sufficient to state a claim for deliberate indifference and thus plaintiff had shown a sufficient likelihood of success on the merits of his preliminary injunction. Plaintiff also alleged a substantial threat of irreparable injury. Finally, the magistrate judge's conclusion that it was improbable that plaintiff could establish that the grant of an injunction would not disserve the public interest was without basis in the record. Accordingly, the court remanded for further proceedings. View "Jones v. TDCJ" on Justia Law

The Fifth Circuit vacated the magistrate judge's denial of a preliminary injunction after plaintiff filed suit alleging that prison officials exhibited deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Plaintiff, a diabetic, specifically alleged that prison officials cancelled his prescribed diet on multiple occasions, forcing him to consume high-sugar meals up to four times a day, contrary to the orders of his unit physician. Construing plaintiff's pro se pleadings liberally, the court held that plaintiff had alleged a pattern of knowing interferences with prescribed medical care for his diabetes, despite his multiple complaints and his official grievance, which were all essentially ignored. Such allegations were sufficient to state a claim for deliberate indifference and thus plaintiff had shown a sufficient likelihood of success on the merits of his preliminary injunction. Plaintiff also alleged a substantial threat of irreparable injury. Finally, the magistrate judge's conclusion that it was improbable that plaintiff could establish that the grant of an injunction would not disserve the public interest was without basis in the record. Accordingly, the court remanded for further proceedings. View "Jones v. TDCJ" on Justia Law

The Fifth Circuit denied the petition for panel rehearing and denied the petition for rehearing en banc. The court withdrew the previous opinion and issued the following opinion.After Jermaine Darden suffered a heart attack and died during his arrest, the administrator of Darden's estate filed suit under 42 U.S.C. 1983 against the arresting officers and the City. The district court granted summary judgment for the officers and the City, and dismissed all claims. The court held that a jury could conclude that no reasonable officer on the scene would have thought that Darden was resisting arrest; Officer Snow was not entitled to qualified immunity where there were genuine disputes of material fact as to whether Darden was actively resisting arrest and whether the force Officer Snow used was clearly excessive and clearly unreasonable; Officer Romero was not entitled to qualified immunity where a reasonable jury could conclude that he used excessive force; and plaintiff adequately alleged facts that made out violations of a clearly established constitutional right. Therefore, the court reversed in part, vacated in part, and remanded. View "Darden v. City of Fort Worth, Texas" on Justia Law

The Fifth Circuit denied the petition for panel rehearing and denied the petition for rehearing en banc. The court withdrew the previous opinion and issued the following opinion.After Jermaine Darden suffered a heart attack and died during his arrest, the administrator of Darden's estate filed suit under 42 U.S.C. 1983 against the arresting officers and the City. The district court granted summary judgment for the officers and the City, and dismissed all claims. The court held that a jury could conclude that no reasonable officer on the scene would have thought that Darden was resisting arrest; Officer Snow was not entitled to qualified immunity where there were genuine disputes of material fact as to whether Darden was actively resisting arrest and whether the force Officer Snow used was clearly excessive and clearly unreasonable; Officer Romero was not entitled to qualified immunity where a reasonable jury could conclude that he used excessive force; and plaintiff adequately alleged facts that made out violations of a clearly established constitutional right. Therefore, the court reversed in part, vacated in part, and remanded. View "Darden v. City of Fort Worth, Texas" on Justia Law

The Fifth Circuit reversed the district court's decision to enjoin the enforcement of federal laws that generally prohibit the direct sale of a handgun by a federally licensed firearms dealer (FFL) to a person who is not a resident of the state in which the FFL is located. The court assumed without deciding, that the strict, rather than intermediate standard for scrutiny was applicable. The court held that the in-state sales requirement did not violate the Second Amendment because it was narrowly tailored to assure that an FFL who actually makes a sale of a handgun to someone other than another FFL can reasonably be expected to know and comply with the laws of the state in which the sale occurs. Furthermore, the in-state sales requirement was not unconstitutional as applied to plaintiffs where the rule advanced government interests in the aggregate. The court also held that the in-state sales requirement did not violate the equal protection guarantee in the Due Process clause of the Fifth Amendment. In this case, the in-state sales requirement did not favor or disfavor residents of any particular state. Instead, it imposed the same restrictions on sellers and purchasers of firearms in each state and the District of Columbia. View "Mance v. Sessions" on Justia Law

The Fifth Circuit reversed the district court's denial of a petition for habeas relief under 28 U.S.C. 2254. The court held that petitioner's Federal Rule of Civil Procedure 59(e) motion was timely filed and tolled the deadline for filing a notice of appeal until the entry of the order disposing of the motion. The court also held that this case presented one of those "extreme situations" in which the court was justified in finding a violation of the Sixth Amendment based on implied juror bias during the punishment phase of his trial. Although petitioner's conviction for possession of methamphetamine must stand, his sentence of life imprisonment could not. Accordingly, the court remanded with instructions. View "Uranga v. Davis" on Justia Law