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

After Wilbert Lee Henson died while in pretrial detention in a jail in Wichita County, his daughters filed suit against the county and medical staff. In this third appeal, plaintiffs challenged the district court's grant of summary judgment in favor of the County and Dr. Daniel Bolin, the physician in charge of the jail. The court found that Dr. Bolin is entitled to summary judgment and affirmed the district court's order in that respect because plaintiffs did not assert a conditions-of-confinement claim against Dr. Bolin, and because, even if they had, such claim would fail. The court further concluded that plaintiffs' evidence falls short of proving that the Wichita County jail’s medical system and staffing policies amounted to punishment, in violation of Henson’s constitutional rights. Therefore, the court also affirmed the district court's order in this respect. View "Estate of Wilbert Lee Henson v. Wichita County" on Justia Law

Plaintiff, a paraplegic inmate, filed suit against several doctors and jailers, claiming that they were deliberately indifferent to his serious medical condition in violation of the Eighth Amendment’s prohibition on cruel and unusual punishment. The district court held that there was a genuine issue of material fact and denied qualified immunity, rejecting the magistrate judge’s contrary recommendation. The court reversed, concluding that the record cannot support a claim of deliberate indifference. In this case, the district court order does not identify the factual disputes that preclude summary judgment on the basis of qualified immunity, even though the magistrate judge’s report makes a strong case to the contrary. View "Brauner v. Coody" on Justia Law

Plaintiff filed suit against his employer, NOV, after he was terminated, alleging claims of age discrimination and retaliation in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, et seq., and the Texas Commission on Human Rights Act (TCHRA), Tex. Lab. Code Ann. 21.051, 21.055. ROA. 22–28. The district court granted summary judgment in favor of NOV and plaintiff appealed. The court concluded that the evidence plaintiff has identified was sufficient to allow a finding that age discrimination was the cause of his termination in violation of the ADEA. However, in regards to the retaliation claim, the court concluded that plaintiff was unable to establish the causal link in light of the temporal gap of 8–10 months between plaintiff’s complaint to HR and the adverse employment action and the absence of evidence that the supervisor even knew of the complaint to Human Resources about the “old farts” comment. Accordingly, the court affirmed as to the retaliation claim but reversed the discrimination claim. The court remanded for further proceedings. View "Goudeau v. National Oilwell Varco, L.P." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 and Mississippi state law against the Bureau and two state agents, alleging that the agents falsely identified him as a participant in a drug ring and caused him to be unlawfully detained for six months. On interlocutory appeal, the court held that the district court erred in denying defendants’ motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). In this case, plaintiff has not stated a claim that defendants violated his federal constitutional rights, and the Mississippi Tort Claims Act, Miss. Code Ann. 11-6-5(1), immunizes defendants from suit under state law. Accordingly, the court reversed and remanded with instructions to dismiss plaintiff's claims. View "Bosarge v. MS Bureau of Narcotics" on Justia Law

Plaintiffs, death-row inmates at a new state-of-the-art prison facility that has no air conditioning, filed suit against the State and various prison officials, alleging that the heat that they endure during the summer months violates the Eighth Amendment because of their pre-existing medical problems. Plaintiffs also allege that the failure to provide air conditioning violates the Americans with Disabilities Act (ADA), 42 U.S.C. 12132, and the Rehabilitation Act (RA), 29 U.S.C. 794. Plaintiffs suffer from various conditions such as hypertension, obesity, diabetes, depression, and high cholesterol. The district court sustained the inmates’ Eighth Amendment claims, rejected their disability claims, and issued an injunction effectively ordering defendants to install air conditioning throughout death row. The court concluded that, although the trial court’s findings of deliberate indifference by prison officials to these particular inmates’ serious heat-related vulnerability suffice to support a constitutional violation, the scope of its injunctive relief exceeds the court's prior precedent, Gates v. Cook, and the Prison Litigation Reform Act (PLRA), 18 U.S.C. 3626. However, the disability claims are insupportable as a matter of law even under the expanded legal definition of disability. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Ball v. LeBlanc" on Justia Law

Plaintiffs are two same-sex couples who seek to marry in Texas or to have their marriage in another state recognized in Texas. The district court subsequently issued a preliminary injunction prohibiting the state from enforcing any laws or regulations prohibiting same-sex couples from marrying or prohibiting the recognition of marriages between same-sex couples lawfully solemnized elsewhere. While the appeal was under submission, the Supreme Court decided Obergefell v. Hodges, which held in part that there is no lawful basis for a State to refuse to recognize a lawful same sex marriage performed in another State on the ground of its same-sex character. Because, as both sides now agree, the injunction appealed from is correct in light of Obergefell, the preliminary injunction is affirmed and the matter remanded for entry of judgment in favor of plaintiffs. View "DeLeon v. Abbott" on Justia Law

Plaintiffs, seven same-sex couples and an organization whose membership includes same-sex couples and their families, seek to marry in Louisiana or to have their marriage in another state recognized in Louisiana. The district court granted summary judgment to defendants. While this appeal was under submission, the Supreme Court decided Obergefell v. Hodges, which held in part that there is no lawful basis for a state to refuse to recognize a lawful same-sex marriage performed in another state on the ground of its same-sex character. Accordingly, the court reversed and remanded for entry of judgment in favor of plaintiffs. View "Robicheaux v. Caldwell" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983 against the County, District Attorney Pat Lykos, and one of her assistants, Rachel Palmer, for causing their termination by the college that had contracted to oversee breath alcohol testing for the Sheriff's Office. Plaintiffs also raised state law claims. The district court dismissed all of the claims. The court reversed the dismissal of plaintiff's claims against the County that it ratified Palmer's and Lykos's alleged retaliatory campaign; reversed the dismissal of the tortious interference with a contract claim; reversed the dismissal of tortious interference claims; and reversed the award of attorneys' fees. The court affirmed in all other respects. View "Culbertson v. Lykos" on Justia Law

Plaintiffs, religious organizations, filed suit under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb to 2000bb-4, challenging a requirement that they either offer their employees health insurance that covers certain contraceptive services or submit a form or notification declaring their religious opposition to that coverage. The district court enjoined the government from enforcing the requirement. The court concluded that the acts plaintiffs are required to perform do not involve providing or facilitating access to contraceptives, and plaintiffs have no right under RFRA to challenge the independent conduct of third parties. Because plaintiffs have not shown that the regulations substantially burden their religious exercise or, in University of Dallas, have not demonstrated a substantial likelihood of doing so, the court need not reach the strict-scrutiny prong or the other requirements for an injunction. Accordingly, the court reversed the judgment of the district court. View "East Texas Baptist Univ. v. Burwell" on Justia Law

Plaintiff filed suit against FISD, alleging that FISD discriminated against him because of his race and retaliated against him for reporting the discrimination, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and the Texas Commission on Human Rights Act (TCHRA), Tex. Labor Code 21.051, 21.055. The court concluded that FISD's collateral-estoppel claim fails because plaintiff did not have an adequate opportunity to litigate his pending discrimination and retaliation claims before the hearing examiner; FISD is not entitled to summary judgment against plaintiff's discrimination claim because FISD conceded at oral argument that there is a genuine dispute for pretext and a genuine dispute of material fact exists for whether the allegedly discriminatory animus is imputed to FISD; and FISD is not entitled to summary judgment against plaintiff's retaliation claim where there is a genuine dispute of material fact for why plaintiff's contract was nonrenewed. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Jackson v. Frisco Indep. Sch. Dist." on Justia Law