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

The case involves healthcare providers and air ambulance services challenging regulations established by the Departments of Health and Human Services, Labor, and the Treasury. These regulations were designed to guide independent arbitrators in resolving insurance reimbursement disputes under the No Surprises Act, which aims to protect patients from unexpected medical bills by limiting their out-of-pocket costs for emergency and certain non-emergency services provided by out-of-network providers.The United States District Court for the Eastern District of Texas reviewed the case and vacated the regulations, finding that they improperly favored the qualifying payment amount (QPA) over other statutory factors that arbitrators are required to consider. The court held that the regulations conflicted with the No Surprises Act and violated the Administrative Procedure Act (APA) by imposing additional requirements not found in the statute. The court also found that the plaintiffs had standing to sue based on procedural and financial injuries.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the regulations exceeded the Departments' authority by imposing a sequence in which arbitrators must consider the QPA first, disregarding information deemed not credible or unrelated, and requiring arbitrators to explain why they deviated from the QPA. The court found that these provisions placed undue emphasis on the QPA, contrary to the statute's requirement that all factors be considered equally. The court also upheld the district court's universal vacatur of the challenged provisions, rejecting the Departments' arguments for more limited relief. View "Texas Medical Association v. Health and Human Services" on Justia Law

The Department of Transportation (DOT) issued a Rule on April 30, 2024, requiring airlines to disclose ancillary service fees, such as baggage and change fees, during the booking process. The Rule aims to protect consumers from surprise charges and is expected to provide significant societal and consumer benefits. The Rule took effect on July 1, 2024, with compliance deadlines for airlines and third-party ticket agents set for later dates. Various airlines and airline associations challenged the Rule, arguing it exceeds DOT’s authority, is arbitrary and capricious, and bypassed the required notice and comment process.The airlines and associations first sought a stay from the DOT, which was denied. They then petitioned the United States Court of Appeals for the Fifth Circuit for a stay pending review. The petitioners argued that the Rule exceeds DOT’s statutory authority under 49 U.S.C. § 41712(a), which allows the DOT Secretary to investigate and adjudicate unfair or deceptive practices but does not authorize the creation of detailed legislative rules. The petitioners also claimed that the Rule imposes significant compliance costs that would cause irreparable harm.The United States Court of Appeals for the Fifth Circuit granted the stay, finding that the petitioners made a strong showing that the Rule likely exceeds DOT’s authority. The court noted that the Rule mandates specific disclosure practices without the adjudicatory process required by the statute. The court also found that the petitioners would suffer irreparable harm due to the nonrecoverable compliance costs. The court concluded that there is no public interest in perpetuating unlawful agency action and expedited the petition for review to the next available oral argument panel. View "Airlines for America v. Department of Transportation" on Justia Law

SO Apartments, LLC and Elm Creek, LLC (the “Complexes”) challenged the City of San Antonio’s Proactive Apartment Inspection Program (PAIP), which was created to address property maintenance code violations. The PAIP requires multifamily apartment complexes with five or more units to enroll if they receive three or more code citations over six months that are not cured. Enrolled complexes are subject to monthly inspections and a $100 per-unit, per-year fee. The Complexes received multiple code violation notices, failed to cure them, and were fined and enrolled in the PAIP, resulting in significant fees.The Complexes filed suit in the United States District Court for the Western District of Texas, arguing that the PAIP violated the Fourth Amendment by allowing warrantless inspections, the Eighth Amendment by imposing excessive fines, and the Fourteenth Amendment by denying procedural and substantive due process. The district court denied their request for a preliminary injunction, finding they failed to show a likelihood of success on the merits, irreparable harm, that the balance of harms favored them, or that an injunction would serve the public interest.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that the PAIP does not authorize warrantless searches, as it does not explicitly state that city officials can conduct searches without a warrant. The $100 per-unit fee was found to be administrative rather than punitive, and thus not excessive under the Eighth Amendment. The court also found that the PAIP provided adequate procedural due process through its notice and appeal processes. Lastly, the court determined that the Complexes failed to show that the PAIP’s requirements were so egregious as to violate substantive due process. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "SO Apartments v. City of San Antonio" on Justia Law

The plaintiffs, five Muslim U.S. citizens, allege they have been placed on the Terrorist Screening Dataset, commonly known as the "terrorist watchlist." This list includes the No-Fly List, which prevents individuals from boarding flights, and the Selectee List, which subjects individuals to enhanced security screening. Four plaintiffs claim they are on the Selectee List due to repeated enhanced screenings, while one plaintiff, Adis Kovac, claims he is on both the No-Fly List and the Selectee List. Each plaintiff sought redress through the Department of Homeland Security’s Traveler Redress Inquiry Program (TRIP), but only Kovac received confirmation of his No-Fly List status.The plaintiffs filed a lawsuit in the U.S. District Court for the Northern District of Texas against various federal agency heads, alleging violations of their constitutional rights and unlawful agency action under the Administrative Procedure Act (APA). The district court dismissed several claims, including due process and equal protection claims, and later dismissed Kovac’s No-Fly List claims as moot after he was removed from the list. The remaining APA claims were addressed at summary judgment, where the district court ruled that the agencies had statutory authority to maintain the watchlist and that the TRIP procedures were not arbitrary and capricious.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that the relevant federal agencies have clear statutory authority to create, maintain, and use the watchlist for screening airline passengers. The court found that the statutory framework, including the Aviation and Transportation Security Act, the Homeland Security Act, and subsequent legislation, provided unambiguous authority for the watchlist. The court did not address whether the major questions doctrine applied, as the statutory authority was clear. The court also concluded that the plaintiffs lacked standing to challenge the watchlist’s use in contexts unrelated to airport security. View "Kovac v. Wray" on Justia Law

A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law

The case involves the estate of Bud Conyers seeking a relator’s share of the proceeds from a settlement between the United States and military contractor Kellogg Brown & Root (KBR) under the False Claims Act (FCA). Conyers, a former KBR truck driver, had filed a qui tam suit alleging various fraudulent activities by KBR, including the use of mortuary trailers for supplies, kickbacks for defective trucks, and billing for prostitutes. The government later intervened in Conyers’s suit but pursued different claims involving KBR employees Mazon, Seamans, and Martin, who were involved in separate kickback schemes.The United States District Court for the Southern District of Texas awarded Conyers’s estate approximately $1.1 million, finding a “factual overlap” between Conyers’s allegations and the settled claims, particularly with Martin’s kickback scheme involving trucks. The court reasoned that Conyers’s allegations had put the government on notice of fraud in trucking contracts, which arguably led to the investigation of Martin. The district court also ordered the government to pay Conyers’s attorney’s fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that under the FCA, a relator is entitled to a share only of the settlement of the claim he brought, not additional claims added by the government. The court found no relevant factual overlap between Conyers’s claims and the settled claims involving Mazon, Seamans, and Martin. The court also rejected the district court’s reasoning that Conyers’s allegations spurred the investigation into Martin’s misconduct, noting that the FCA does not entitle a relator to recover from new claims discovered by the government. Consequently, the Fifth Circuit concluded that Conyers’s estate was not entitled to any share of the settlement proceeds and reversed the award of attorney’s fees. View "USA v. Conyers" on Justia Law

Dobbin Plantersville Water Supply Corporation (Dobbin) held a Certificate of Convenience and Necessity (CCN) to provide water service in certain areas of Texas. Dobbin, a recipient of federal loans under 7 U.S.C. § 1926, which grants monopoly protection to loan recipients, faced decertification petitions from developers SIG Magnolia L.P. and Redbird Development L.L.C. The Public Utility Commission of Texas (PUC) granted these petitions, finding that Dobbin was not providing actual water service to the developers' properties. Dobbin then filed a lawsuit in federal court, arguing that the Texas Water Code section allowing decertification was preempted by federal law.The United States District Court for the Western District of Texas dismissed Dobbin's 42 U.S.C. § 1983 claims against the PUC officials, concluding they were not appropriate defendants under § 1983. At the summary judgment stage, the district court dismissed Dobbin's remaining claims with prejudice, primarily on jurisdictional grounds. The court found that Dobbin lacked a cause of action against the developers and that an injunction against the PUC would not redress Dobbin's injuries.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Dobbin lacked standing to seek an injunction against the PUC officials because such relief would not redress its injuries. The court also upheld the dismissal of Dobbin's § 1983 claim against the PUC officials, reiterating that state officials in their official capacities are not "persons" under § 1983. Lastly, the court found no abuse of discretion in the district court's decision to dismiss Dobbin's claims against the developers with prejudice, as Dobbin lacked a viable cause of action against them. View "Dobbin Plantersville Water Supply Corporation v. Lake" on Justia Law

Joshua Jones applied for disability insurance benefits (DIB) and supplemental security income (SSI) on October 1, 2019, citing various medical conditions including disc herniation, diabetes, and high blood pressure. His applications were denied initially and upon reconsideration. Jones then requested a hearing before an administrative law judge (ALJ), which took place on August 5, 2021. The ALJ denied his claims on October 6, 2021. Jones appealed to the Appeals Council, which denied review. Subsequently, he sought judicial review in the United States District Court for the Eastern District of Louisiana, which upheld the Commissioner’s decision.The district court reviewed cross-motions for summary judgment and adopted the magistrate judge’s recommendation to deny Jones’ motion and grant the Commissioner’s motion. The court found that the ALJ had applied the correct legal standards and that substantial evidence supported the decision. Jones then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court’s judgment. The court held that the ALJ correctly applied Listing 1.15, which became effective on April 2, 2021, rather than the older Listing 1.04, to evaluate Jones’ claims. The court found that applying the new listing to pending claims did not constitute impermissible retroactivity. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence, including the finding that Jones did not meet the criteria for medical equivalency under Listing 1.15. The court also concluded that the ALJ properly considered the impact of Jones’ medical treatments on his ability to maintain employment, finding no evidence that his treatment regimen significantly interrupted his ability to work. View "Jones v. O'Malley" on Justia Law

The plaintiff, Shanita Terrell, alleges that two deputies from the Harris County Sheriff’s Office forced her into a patrol car, and one of them sexually assaulted her. The deputies were off-duty but were in uniform and using patrol vehicles while working side jobs at a bar. Terrell woke up the next morning at home with pain in her vaginal area and no memory of having sex. A DNA test revealed that semen in her underwear matched one of the deputies, Michael Hines. Hines was later charged with sexually assaulting Terrell.Terrell sued Deputy Hines, Deputy Mark Cannon, Harris County Sheriff Ed Gonzalez, and Harris County under 42 U.S.C. § 1983. The district court dismissed her claims against Cannon, Gonzalez, and Harris County for failing to state a claim. Terrell appealed the dismissal.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that Terrell failed to establish that Deputy Cannon violated a clearly established constitutional right. She also failed to allege the type of pattern of deliberate indifference required to establish liability for the County or its Sheriff. The court also dismissed Terrell's supervisory and municipal liability claims against Sheriff Gonzalez and Harris County, respectively. The court concluded that Terrell's allegations were insufficient to show a failure-to-train policy or a widespread pattern of misconduct. View "Terrell v. Harris County" on Justia Law

The case involves Lion Elastomers, a synthetic rubber manufacturer, and the National Labor Relations Board (NLRB). Lion Elastomers had been found guilty of unfair labor practices by the NLRB for threatening, disciplining, and discharging an employee, Joseph Colone, for engaging in protected activities. The NLRB applied the Atlantic Steel standard to assess whether Colone's behavior lost its protected status. However, before the appeal of the Board’s decision had been briefed, the NLRB issued a new interpretation of the National Labor Relations Act (NLRA) in a case called General Motors, which overruled Atlantic Steel. The NLRB then sought a remand to apply this new interpretation to the Lion Elastomers case.The case was remanded to the NLRB by the Fifth Circuit Court of Appeals. However, instead of applying the new interpretation from General Motors as expected, the NLRB used the remand proceeding to overrule General Motors and return to the Atlantic Steel standard. Lion Elastomers argued that the NLRB exceeded the scope of the remand and violated its due-process rights during the remand proceeding.The Fifth Circuit Court of Appeals agreed with Lion Elastomers. The court found that the NLRB had exceeded the scope of the remand by not applying the General Motors standard as expected. The court also found that the NLRB had violated Lion Elastomers's due-process rights by not giving the company an opportunity to be heard before deciding to overturn General Motors. The court vacated the NLRB's decision and remanded the case back to the NLRB, instructing it to apply the General Motors standard to this case. View "Lion Elastomers v. National Labor Relations Board" on Justia Law