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

The case involves the American Rescue Plan Act (ARPA), which allocated nearly $200 billion to states and the District of Columbia to assist with economic recovery following the COVID-19 pandemic. However, to accept the funds, states had to agree not to use them to "directly or indirectly offset" reductions in state tax revenue. The states of Texas, Louisiana, and Mississippi filed a lawsuit seeking to enjoin the enforcement of this provision, arguing that it was unconstitutionally ambiguous and violated the Spending Clause and the anticommandeering doctrine.The district court granted summary judgment in favor of the states, finding that the provision was unduly coercive and commandeered the states. It held that the amount of money at stake was too great to present the states with a real choice and that the provision unlawfully forced the states to adopt certain tax policies. The court permanently enjoined the enforcement of the provision, and the federal defendants appealed.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the provision was impermissibly ambiguous and fell short of Congress's constitutional obligation to clearly outline the conditions for states accepting federal funding. The court held that the provision violated the Spending Clause's requirement for clarity, as it left states unable to determine the terms of the deal they were agreeing to. The court also affirmed the district court's grant of a permanent injunction against the enforcement of the provision. View "State of Texas v. Yellen" on Justia Law

A group of individuals and businesses challenged the Affordable Care Act's requirement for private insurers to cover certain types of preventive care, including contraception, HPV vaccines, and drugs preventing HIV transmission. The plaintiffs argued that the mandates were unlawful because the agencies issuing them violated Article II of the Constitution, as their members were principal officers of the United States who had not been validly appointed under the Appointments Clause. The district court mostly agreed, vacating all agency actions taken to enforce the mandates and issuing both party-specific and universal injunctive relief.The United States Court of Appeals for the Fifth Circuit agreed that the United States Preventive Services Task Force, one of the challenged administrative bodies, was composed of principal officers who had not been validly appointed. However, the court found that the district court erred in vacating all agency actions taken to enforce the preventive-care mandates and in universally enjoining the defendants from enforcing them. The court also held that the Secretary of the Department of Health and Human Services had not validly cured the Task Force’s constitutional problems.The court affirmed in part, reversed in part, and remanded the case for further proceedings. The court did not rule on the plaintiffs' challenges against the other two administrative bodies involved in the case, the Advisory Committee on Immunization Practices and the Health Resources and Services Administration, reserving judgment on whether the Secretary had effectively ratified their recommendations and guidelines. View "Braidwood Mgmt v. Becerra" on Justia Law

Randal Hall filed a civil rights case against Officer Travis Trochesset and the City of League City, Texas, alleging constitutional violations following his arrest for interference with a police investigation. The incident began when Hall's wife was involved in a minor car accident. The other driver reported the incident as a hit-and-run, leading to an investigation by Officer Trochesset. When Trochesset arrived at the Halls' home to gather information, Hall, who was not present, instructed his wife over the phone not to provide the requested information to Trochesset. As a result, Trochesset obtained an arrest warrant for Hall for interfering with public duties.The United States District Court for the Southern District of Texas dismissed Hall's suit, ruling in favor of Trochesset and the City of League City. Hall appealed the decision.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that probable cause existed for Hall's arrest, as Hall had interfered with Trochesset's investigation. The court also applied the independent intermediary doctrine, which states that an officer who presents all relevant facts to an impartial intermediary (in this case, a justice of the peace) is not liable if the intermediary's independent decision leads to an arrest. The court found that Trochesset had not withheld any relevant information from the justice of the peace. Furthermore, the court ruled that Hall failed to establish that Trochesset violated the Fourth or Fourteenth Amendments. The court also dismissed Hall's claim against the City of League City, as there was no constitutional violation by Trochesset, and Hall failed to identify an official policy or custom that led to the alleged violation. The court rejected Hall's argument to discontinue the application of the qualified immunity doctrine, stating that it is bound by the Fifth Circuit rule of orderliness to follow established precedent. View "Hall v. Trochessett" on Justia Law

The case involves a group of civil rights organizations, voters, and an election official who sought to challenge recent amendments to Texas's election code, alleging that these amendments violated the United States Constitution and several federal statutes. The defendant was the District Attorney for Harris County, sued in her official capacity. The district court denied the District Attorney's motion to dismiss, holding that she was not immune from the plaintiffs' constitutional claims and that the plaintiffs had standing to bring their claims against her.The United States Court of Appeals for the Fifth Circuit held that it had jurisdiction to hear the appeal and that the district court should have dismissed the plaintiffs' constitutional claims as barred by sovereign immunity. The court did not reach the issue of standing. The court reversed in part, vacated in part, and remanded the case for further proceedings.The court's decision was based on the principle of sovereign immunity, which generally protects state officials from being sued in their official capacities. However, there is an exception to this rule, known as the Ex parte Young exception, which allows federal courts to enjoin state officials from enforcing unconstitutional state statutes. The court found that the District Attorney did not have a sufficient connection to the enforcement of the challenged laws to fall within this exception. Therefore, the court concluded that the District Attorney was immune from the plaintiffs' constitutional claims. View "Mi Familia Vota v. Ogg" on Justia Law

The case involves two casino operators, PNK (Baton Rouge) Partnership, PNK Development 8 LLC, PNK Development 9 LLC, and Centroplex Centre Convention Hotel, LLC, who incentivize their patrons with rewards, including complimentary hotel stays. The City of Baton Rouge/Parish of East Baton Rouge Department of Finance and Linda Hunt, its director, discovered through an audit that the operators had not remitted state and local taxes associated with these complimentary stays for several years. The City argued that the operators needed to pay these taxes, while the operators presented various arguments as to why they did not. The City filed a lawsuit in state court, which the operators removed to federal court on diversity jurisdiction grounds.The operators' removal of the case to federal court was challenged by the City, which argued that the tax abstention doctrine (TAD) warranted abstention in this case. The United States District Court for the Middle District of Louisiana agreed with the City, finding that all five TAD factors favored abstention: Louisiana's wide regulatory latitude over its taxation structure, the lack of heightened federal court scrutiny required by the operators' due process rights invocation, the potential for the operators to seek an improved competitive position in the federal court system, the greater familiarity of Louisiana courts with the state's tax regime and legislative intent, and the constraints on remedies available in federal court due to the Tax Injunction Act.The United States Court of Appeals for the Fifth Circuit affirmed the District Court's decision. The Appeals Court found that the District Court had correctly applied the TAD and had not abused its discretion in deciding to abstain. The Appeals Court agreed that all five TAD factors favored abstention and that any doubt about the propriety of removal should be resolved in favor of remand. View "City of Baton Rouge v. PNK" on Justia Law

The case revolves around Deborah Strickland, an employee of the Department of Veterans Affairs (VA), who was suspended for 15 days without pay following a series of incidents involving her supervisor. Strickland appealed her suspension to the Merit Systems Protection Board (MSPB), claiming disability discrimination. The MSPB refused to consider the entire disciplinary decision after determining one part of the decision was correct. Strickland then appealed to the district court, which affirmed the MSPB's decision.The district court upheld the MSPB's decision and dismissed Strickland's Rehabilitation Act claims. Strickland then appealed to the United States Court of Appeals for the Fifth Circuit. The Court of Appeals found that the MSPB erred in refusing to review the VA's entire disciplinary decision and that both the MSPB and the VA erred by failing to analyze the non-exhaustive factors articulated in Douglas v. Veterans Admin. The Court of Appeals vacated the district court's and the MSPB's orders, reversed the district court in part, and remanded to the district court with instructions to remand to the MSPB for additional proceedings consistent with its opinion. View "Strickland v. Wilkie" on Justia Law

Barbara Harrison, a severely disabled individual, challenged the Texas Health and Human Services Commission's (HHSC) decision to deny funding for medical services she claimed were necessary for her survival. Harrison lived in a group home and received nursing services funded by HHSC’s program for providing home and community-based care to people with disabilities. However, when her condition deteriorated to the point where she required 24/7 one-on-one nursing care, HHSC determined that the cost of providing Harrison’s necessary level of care exceeded the cost cap set by the program. Harrison was therefore denied program-funded nursing services, meaning her only option for receiving government-funded medical care was to move to an institutional setting.Harrison challenged HHSC’s determination in court, arguing that HHSC discriminated against her because of her disability, in violation of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, by denying her program-funded nursing services. The district court granted a preliminary injunction requiring HHSC to fund 24/7 one-on-one care for Harrison until she received a hearing on her request for general revenue funds. However, the United States Court of Appeals for the Fifth Circuit vacated the preliminary injunction and remanded for further proceedings, holding that Harrison was unlikely to succeed on her due process claim and had not demonstrated a likelihood of success on the ADA/Rehabilitation Act claims.After the case was remanded to the district court, Harrison submitted a new application to HHSC for 24-hour nursing care under the Program, the cost of which again exceeded the Cost Cap. HHSC determined that Harrison did not require 24-hour nursing care and that 5.5 hours of nursing care per day would be sufficient to meet her medical needs. The district court found that Harrison’s change in status— from receiving no Program funding to receiving some Program funding— mooted Harrison’s ADA/Rehabilitation Act claims. The court therefore dismissed them and then granted summary judgment to HHSC on Harrison’s due process claim. Harrison appealed this decision.The Fifth Circuit Court of Appeals affirmed the district court’s grant of summary judgment to HHSC on Harrison’s due process claim but reversed the district court’s dismissal of Harrison’s discrimination claims. The court found that the district court’s mootness determination was erroneous and that the factual record was still not sufficiently developed to support a judgment as to Harrison’s discrimination claims. The case was remanded for further factfinding and proceedings. View "Harrison v. Young" on Justia Law

The case involves Disability Rights Texas (DRTx), an advocacy organization for individuals with mental illness, and Houston Behavioral Healthcare Hospital (Houston Behavioral). DRTx sought to compel Houston Behavioral to disclose video footage related to the involuntary confinement of its client, G.S., who alleged abuse during his detention at the hospital. G.S. had signed a waiver allowing DRTx to access his records. Houston Behavioral initially cooperated with DRTx's requests for information but refused to provide the requested video footage, citing confidentiality regulations related to substance use disorder treatment.The United States District Court for the Southern District of Texas granted summary judgment in favor of DRTx and issued an injunction, compelling Houston Behavioral to disclose the video footage. Houston Behavioral appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that the Protection and Advocacy for Individuals with Mental Illness Act (PAIMI Act) grants broad investigatory powers to organizations like DRTx, including access to "all records of any individual." The court held that the video footage requested by DRTx falls within the definition of "records" under the PAIMI Act. The court also found that the Health Insurance Portability and Accountability Act (HIPAA) does not bar the disclosure of such records, as the required-by-law exception in HIPAA permits disclosure when another law, such as the PAIMI Act, requires it. The court concluded that Houston Behavioral's refusal to provide the video footage violated the PAIMI Act. View "Disability Rights Texas v. Hollis" on Justia Law

In 2017, Terry Bevill, a captain of the Quitman Police Department, signed an affidavit supporting a motion to transfer venue in a criminal case against his friend and former colleague, David McGee. Bevill's affidavit alleged potential bias in the local justice system, including personal relationships between the sheriff, the district attorney, and the presiding judge. Following an investigation, Quitman Mayor David Dobbs terminated Bevill's employment, concluding that Bevill's affidavit violated two police department policies. Bevill filed a lawsuit claiming First Amendment retaliation and conspiracy to retaliate against him for his speech.Previously, the district court denied motions to dismiss the case filed by Sheriff Castloo, District Attorney Wheeler, and Judge Fletcher, who claimed qualified immunity. The United States Court of Appeals for the Fifth Circuit affirmed this decision. Now, the same court is reviewing the district court's denial of the defendants' motions for summary judgment.The court affirmed the district court's decision. It found that Bevill spoke as a citizen on a matter of public concern when he submitted his affidavit. The court also held that Bevill's interest in his speech outweighed the government's interest in the efficient provision of public services. The court concluded that Bevill's constitutional rights were clearly established, and the defendants were not entitled to qualified immunity. The court also held that District Attorney Wheeler was not entitled to prosecutorial immunity. The court noted that it lacked jurisdiction to review the district court's finding that there was sufficient evidence for a jury to infer that the defendants conspired to terminate Bevill's employment in retaliation for his speech. View "Bevill v. Wheeler" on Justia Law

Darion Benjamin Woods pleaded guilty to damaging the property of a foreign official in the United States. Woods and his co-defendant broke into the British Consul General’s family home in Houston, Texas, stealing various items and causing over $50,000 in damages. Woods was arrested and charged with one count of damaging property occupied by a foreign official. He pleaded guilty without a plea agreement. The presentence investigation report calculated Woods’s Guidelines imprisonment range at 12 to 18 months. Woods objected to the report, seeking a two-level reduction for acceptance of responsibility.The district court awarded Woods’s requested two-point reduction for acceptance of responsibility and calculated the Guidelines range at 8–14 months. However, the court varied upwards and sentenced Woods to 30 months in prison. The court concluded that this sentence was necessary to satisfy the 3553(a) factors and to protect the community given Woods’s prior criminal history. The court also ordered Woods to pay $56,636.15 in restitution and imposed a 3-year term of supervised release. Woods timely appealed, arguing that his above-Guidelines sentence is substantively unreasonable and that the condition in the written judgment that he must “refrain from the excessive use of alcohol” conflicts with the oral pronouncement that “while in the program, he’s not to consume alcohol excessively.”The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the district court did not abuse its discretion in sentencing Woods to 30 months in prison, which was above the Guidelines range. The court also found that the written condition of supervised release that Woods must "refrain from the excessive use of alcohol" conflicted with the oral pronouncement that "while in the program, he’s not to consume alcohol excessively." The court modified the sentence to reflect that while Woods is in the drug-treatment program, he’s not to consume alcohol excessively. View "United States v. Woods" on Justia Law