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

The Constitution does not require that officers always take arrestees suspected to be under the influence of drugs or alcohol, or reported by relatives to be at risk, to a hospital against their wishes. Diana Simpson's family filed suit under 42 U.S.C. 1983, alleging that the county violated Simpson's constitutional rights when she died in the county jail from a probable suicide-caused drug overdose the evening after she was arrested for public intoxication. The district court granted summary judgment to the county and dismissed the complaint. The court held that, although Simpson's decision to take her own life was tragic, the county could not be held responsible for fatal decisions she made that were, under all the circumstances, not obvious to government employees. Accordingly, the court affirmed the judgment to the extent it rejected plaintiffs' episodic acts and omissions claim. The court vacated and remanded for consideration in the first instance of plaintiffs' unconstitutional conditions of confinement claim. View "Sanchez v. Young County, Texas" on Justia Law

Plaintiff, an inmate in custody and an adherent to the Rastafari religion who has dread locks, filed suit seeking a declaration that the Department of Corrections grooming policies violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and an injunction against the grooming policies being applied to him. The Fifth Circuit reversed the district court's denial of relief, holding that the Department failed to satisfy its burden to show the polices were the least restrictive means of serving a compelling interest. In this case, the Department had a full and fair opportunity during a two-day bench trial to satisfy this burden. The court rendered judgment granting plaintiff's request for a declaration that the grooming policies, as applied to him, violated RLUIPA and enjoining the Department from enforcing the grooming policies against him. View "Ware v. Louisiana Department of Corrections" on Justia Law

Petitioner, an insanity acquittee who has been in the custody of the Eastern Louisiana Mental Health System (ELMHS) since 1999, appealed the denial of his petition for habeas relief under 28 U.S.C. 2254. The Fifth Circuit noted that it was troubled that the state court seemingly failed to follow Louisiana state law in denying petitioner relief, but held that the state court decision was not contrary to clearly established Supreme Court law. In this case, petitioner did not make any clear, independent argument that the state court's denial of conditional release involved an unreasonable application of clearly established Supreme Court law. View "Poree v. Collins" on Justia Law

In this appeal stemming from the desegregation of the school district, the Fifth Circuit affirmed the district court's rejection of the School Board's latest proposed candidate, approving instead the candidate supported by plaintiffs and the Court Compliance Officer. The court held that the district court did not abuse its discretion in modifying the academic-qualifications requirement and the selection-and-approval process. The court also held that the district court did not err by denying the motion for relief from judgment under Fed. R. Civ. P. 60(b) where a candidate's role with the Ministerial Alliance did not justify holding that the district court abused its discretion in appointing the candidate as Chief Desegregation Implementation Officer (CDIO). View "Moore v. Tangipahoa Parish School Board" on Justia Law

The Fifth Circuit reversed the district court's grant of habeas relief based on his claim of ineffective assistance of trial counsel at the penalty phase. The court held that counsel's performance in raising and developing petitioner's claim for ineffective assistance of trial counsel at the penalty phase was not deficient. Furthermore, petitioner failed to establish prejudice. View "Wessinger v. Vannoy" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment against plaintiff on his failure to accommodate and hostile work environment claims. Because plaintiff failed to brief his intentional infliction of emotional distress claim, the court confined its review to his Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., claims. The court held that plaintiff's failure to accommodate claim was unexhausted and plaintiff failed to provide sufficient evidence showing that defendants knew of his disability. The court also held that plaintiff failed to demonstrate that either defendant failed to take prompt, remedial action addressing the alleged harassment. View "Patton v. Jacobs Engineering Group, Inc." on Justia Law

The Fifth Circuit affirmed the district court's denial of habeas relief. The court held that petitioner's Sixth Amendment right to a speedy trial was not violated; his due process and Confrontation Clause rights were not violated when he could not cross-examine his brother on the brother's alleged violence; and petitioner's right to present a complete defense and present witnesses were not violated when his expert on confessions and interrogations was barred from testifying. View "Boyer v. Vannoy" on Justia Law

Petitioner was convicted of killing his wife's parents and sentenced to death. In this appeal, the Fifth Circuit reversed the district court's denial of appointed counsel and expert funding under 18 U.S.C. 3599, vacated its factual findings relating to petitioner's competency, and remanded for additional proceedings. The court held that petitioner was entitled to counsel to pursue his claim because Texas's application of Article 46.05 of the Texas Code of Criminal Procedure denied him due process. Furthermore, the court did not see justification for denying petitioner funding for experts and other investigative resources. Because the district court's conclusion was tainted by the inadequate due process protection provided to petitioner by the State, the court vacated the district court's findings of fact regarding his competency to be executed. View "Panetti v. Davis" on Justia Law

The Fifth Circuit affirmed the district court's judgment for defendants in this civil rights case involving claims arising from the execution of a search warrant on plaintiff's house. The court held that the district court did not err in denying plaintiff's motion to remand; the state court did not err in dismissing the common law claims against the officers pursuant to section 101.106(e) of the Texas Tort Claims Act; the district court properly dismissed plaintiff's federal claims against the individual officers; because plaintiff's negligence claims arose from the same conduct as his intentional-tort claims, governmental immunity applied and the state-law claims were properly dismissed; plaintiff failed to allege a claim of municipal liability under 42 U.S.C. 1983 because he never alleged either an official policy or a widespread custom that caused a violation of his constitutional rights; plaintiff's requested period of discovery was impermissible; and the court rejected plaintiff's claim for punitive damages. Finally, the court denied as moot the individual defendants' motion to dismiss. View "Quinn v. Guerrero" on Justia Law

To reset the accrual date, a change to an execution protocol must be substantial, and any new accrual date is applicable only to the portion of the protocol that changed. The switch from manufactured to compounded pentobarbital was not a substantial change because the switch between two forms of the same drug does not significantly alter the method of execution. In this case, the Fifth Circuit affirmed the district court's dismissal of plaintiffs' complaint under 42 U.S.C. 1983, challenging their method of execution. The court held that the district court properly dismissed Counts One, Two, and part of Three as time-barred. Even if the claims were timely, plaintiffs failed to state a claim with regard to Count Three, which addresses the method-of-execution claims regarding the compounded pentobarbital; Counts One and Four, which deal with plaintiffs' alleged inability to access information about their method of execution; and Count Two, which alleges the right to counsel during the events leading up to and during the execution. The court also held that the district court did not apply a heightened pleading standard; the district court did not consider evidence outside the pleadings; and any discovery error was harmless because plaintiffs were not entitled to discovery without a properly pleaded complaint. View "Whitaker v. Collier" on Justia Law