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

Sharon Lewis, a former employee of Louisiana State University (LSU) football department, reported sexual harassment by former head football coach Les Miles and assistant coach Frank Wilson. She claimed retaliation for these reports, including exclusion from meetings, restructuring of her position, and eventual termination in 2022. Lewis filed a lawsuit under Titles IX and VII against the LSU Board of Supervisors, alleging retaliation and hostile work environment.The United States District Court for the Middle District of Louisiana held a six-day trial, after which the jury found in favor of the Board on all claims. The district court entered judgment accordingly. Lewis filed a renewed motion for judgment as a matter of law or, alternatively, for a new trial, which the district court denied. Lewis then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s judgment and denial of Lewis’s motions. The appellate court found that the jury had a legally sufficient evidentiary basis to conclude that Lewis’s termination was part of a broader restructuring initiative by new head coach Brian Kelly, rather than retaliation for her Title IX and Title VII complaints. The court noted that Kelly and other key decision-makers were unaware of Lewis’s prior complaints at the time of her termination. The court also found no abuse of discretion in the district court’s denial of a new trial, as the jury’s verdict was supported by the evidence presented. View "Lewis v. Board of Supervisors of Louisiana State University" on Justia Law

Former employees of Shriners Hospitals for Children were terminated for refusing to get a COVID-19 vaccination. They sued their employer, its agents, and the Executive Commissioner of Texas Health and Human Services, alleging violations of their right to refuse the vaccine under 42 U.S.C. § 1983, the Emergency Use Authorization (EUA) Statute, and various Texas state laws.The United States District Court for the Southern District of Texas dismissed all claims. It found no personal jurisdiction over the agents due to the fiduciary shield doctrine, determined that Shriners was not a state actor when it implemented the vaccination policy, and ruled that the EUA Statute did not apply. The court also dismissed the claims against the Commissioner, concluding she was not liable for failing to stop Shriners from enforcing the policy. The state-law claims were dismissed for lack of supplemental jurisdiction.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It agreed that there was no personal jurisdiction over the agents and that Shriners was not a state actor when it adopted the vaccination policy. The court also held that the EUA Statute did not apply to Shriners in its capacity as an employer and that the Commissioner was entitled to qualified immunity because the plaintiffs did not demonstrate a clearly established right requiring her intervention. The appellate court modified the dismissal of the state-law claims to be without prejudice and affirmed the judgment as modified. View "Pearson v. Shriners Hospitals" on Justia Law

ExxonMobil Technology and Engineering Company (Exxon) operates a research facility in New Jersey where approximately 165 employees are represented by the Independent Laboratory Employees Union (the Union). The collective bargaining agreement (CBA) between Exxon and the Union expired in May 2018. During negotiations for a new CBA, disputes arose over Exxon’s personal time off (PTO) policies and paid parental leave (PPTO). The Union wanted to restore a policy allowing supervisors to review PTO requests and sought eight weeks of PPTO for its members. Exxon refused to negotiate on these issues, citing concerns over inconsistencies and potential grievances.An administrative law judge (ALJ) found that Exxon violated the National Labor Relations Act by refusing to bargain in good faith on the supervisor PTO review issue, retaliating against the Union for past grievances, and suggesting that employees would receive PPTO if they decertified the Union. The National Labor Relations Board (NLRB) initially reversed the ALJ’s findings in a 2020 decision. However, it was later discovered that a Board member involved in the decision had a conflict of interest, leading the NLRB to vacate the 2020 decision and reconsider the case.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the NLRB did not abuse its discretion in vacating the 2020 decision due to the conflict of interest. The court also upheld the NLRB’s findings that Exxon refused to bargain in good faith on the supervisor PTO review issue and retaliated against the Union for past grievances. Additionally, the court supported the NLRB’s conclusion that Exxon unlawfully suggested employees would receive PPTO if they left the Union. The court denied Exxon’s petition for review and granted the NLRB’s cross-petition for enforcement of its order. View "ExxonMobil v. National Labor Relations Board" on Justia Law

Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law

Douglas Ramsey, the plaintiff, sued his former employer, Sheet Pile, L.L.C., for breach of his employment agreement and a promissory note under which he had loaned the company money. Sheet Pile counterclaimed for breach of the employment agreement and sought an injunction to force Ramsey to return confidential information. Ramsey largely succeeded at trial, receiving an award for prejudgment interest and the denial of Sheet Pile’s requested injunction. Sheet Pile appealed, challenging the jury instructions, sufficiency of the evidence, the grant of prejudgment interest, and the denial of injunctive relief.The United States District Court for the Western District of Texas oversaw the initial trial. The jury found in favor of Ramsey, awarding him the final $5,000 of his salary and $155,878.47 in damages on the loan. The jury also found that Ramsey breached the employment agreement but was not liable due to Sheet Pile’s prior material breach. After the trial, the district court awarded Ramsey prejudgment interest and denied Sheet Pile’s request for a permanent injunction. Sheet Pile filed a post-judgment motion reiterating its arguments, which the district court denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s decisions on the jury instructions and the finding of prior material breach. However, it vacated the award of prejudgment interest, finding that the jury had improperly included interest in its damages award, leading to a double recovery. The court remanded the case for the district court to offer a remittitur based on the amount owed on the loan as of the date Ramsey filed suit. The court also instructed the district court to consider an injunction requiring Ramsey to return any documents containing confidential information. The court affirmed in part, vacated in part, and remanded for further proceedings. View "Ramsey v. Sheet Pile" on Justia Law

Annette Rodriguez, the plaintiff, served as the Director of the City of Corpus Christi and Nueces County Public Health District. Her salary was split between the City and the County. In 2019, the City increased her salary to 90% of the market rate. During the COVID-19 pandemic, Rodriguez requested and initially received overtime pay, but the City later stopped these payments. Rodriguez faced several allegations of policy violations and creating a hostile work environment, leading to a disciplinary memorandum. Despite a positive evaluation from the County, the City terminated her in 2022 and hired a new director.Rodriguez sued the City in the United States District Court for the Southern District of Texas, claiming violations under the Equal Pay Act, Fair Labor Standards Act (FLSA), Title VII, and 42 U.S.C. § 1983. The district court dismissed her Section 1983 claim on the pleadings, finding she did not allege a constitutionally protected interest in continued employment. The court granted summary judgment to the City on the remaining claims, concluding Rodriguez was exempt from FLSA overtime pay requirements, did not establish the equal-work or equal-pay prongs of her EPA claim, and failed to identify a proper comparator for her Title VII claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's rulings, agreeing that Rodriguez did not engage in protected activity under the FLSA, failed to identify a proper comparator for her Title VII and EPA claims, and did not establish pretext for retaliation. The court also found that Rodriguez remained an exempt employee despite receiving additional overtime pay temporarily. The court concluded that the City paid Rodriguez on a salary basis, maintaining her exempt status under the FLSA. View "Rodriguez v. City of Corpus Christi" on Justia Law

Three states challenged an executive order issued by President Joseph R. Biden, which mandated that federal contractors pay their workers a minimum hourly wage of $15. The states argued that the President exceeded his authority under the Federal Property and Administrative Services Act (FPASA) and that the order violated the Administrative Procedure Act (APA) and the nondelegation doctrine. The district court for the Southern District of Texas agreed with the states, finding that the FPASA did not grant the President broad authority to set minimum wages for federal contractors and that the executive order was a major question beyond the President's authority. The court permanently enjoined the executive order.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court examined whether the executive order was a permissible exercise of the President's authority under the FPASA. The court found that the FPASA's language was clear and unambiguous, granting the President broad authority to prescribe policies necessary to carry out the Act's provisions, as long as those policies were consistent with the Act. The court determined that the executive order met these requirements, as it aimed to promote economy and efficiency in federal procurement by ensuring contractors paid their workers adequately.The Fifth Circuit also addressed the application of the major questions doctrine, concluding that it did not apply in this case because the FPASA's text was clear and unambiguous. The court noted that the President's exercise of proprietary authority in managing federal contracts did not raise a major question requiring clear congressional authorization. Consequently, the court reversed the district court's permanent injunction and remanded the case for further proceedings consistent with its opinion. View "State of Texas v. Trump" on Justia Law

Dr. Zahra Shahrashoob, an Iranian woman, was hired by Texas A&M University (A&M) in 2018 for a non-tenure-track position in the Department of Chemical Engineering. Initially employed as a lecturer, she was later reclassified as an instructional assistant professor. Despite her satisfactory performance, she felt discriminated against due to her workspace, salary, and teaching load, leading her to file a discrimination charge in June 2020. In August 2020, A&M offered her a shortened four-and-a-half-month contract, which ended in January 2021. She filed a second discrimination charge, alleging that Dr. Mohammad Alam, an Indian man, was hired to replace her.The United States District Court for the Southern District of Texas granted A&M’s motion for summary judgment, dismissing Dr. Shahrashoob’s claims. The court found that she failed to establish a prima facie case of discrimination as she did not show that she was treated less favorably than similarly situated employees. Additionally, the court concluded that she could not prove that A&M’s reasons for her nonrenewal were pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Dr. Shahrashoob forfeited her arguments regarding Dr. Alam by not raising them sufficiently in the lower court. Even if she had not forfeited these arguments, she failed to make out a prima facie case of discrimination as she did not provide sufficient evidence that Dr. Alam was similarly situated or that he replaced her. Regarding her retaliation claim, the court found that she could not show that A&M’s reasons for her nonrenewal were pretextual, as she did not provide significant evidence beyond temporal proximity. Thus, the court affirmed the summary judgment in favor of A&M. View "Shahrashoob v. Texas A&M University" on Justia Law

Sarah Lindsley filed a discrimination lawsuit against her employer, Omni Hotels Management Corporation, alleging sex-based pay discrimination under the Equal Pay Act (EPA) and Title VII of the Civil Rights Act of 1964. Lindsley claimed that her initial salary was set too low due to her sex, causing her to earn less than her male colleagues despite subsequent raises. She also alleged that she faced harassment and that her complaints about pay discrepancies were ignored.The United States District Court for the Northern District of Texas initially granted summary judgment in favor of Omni on all claims. However, the United States Court of Appeals for the Fifth Circuit reversed and remanded the case for trial on the pay-discrimination claims under Title VII and the EPA. At trial, the jury found Omni not liable under the EPA but awarded Lindsley over $25 million in Title VII damages despite finding no liability under Title VII. The district court deemed the jury's answers inconsistent, amended the verdict form, and ordered further deliberation. The jury then found for Lindsley on her Title VII claim, again awarding over $25 million in damages, which the district court reduced under the statutory cap.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the district court did not err in handling the first verdict form but did err in handling the second verdict form. The appellate court found that the jury's answers in the second verdict form were inconsistent, as they found that any pay disparity resulted from a factor other than sex (an affirmative defense to both the EPA and Title VII claims) but still awarded Title VII damages. The court vacated the district court's judgment and remanded the case for a new trial. View "Lindsley v. Omni Hotels" on Justia Law

Derek Hall, a Senior Account Executive at UiPath Incorporated, alleged retaliation under the Age Discrimination in Employment Act (ADEA) after being placed on a Performance Improvement Plan (PIP) and subsequently terminated. Hall, who was 62 years old, filed an internal complaint against his supervisor for age discrimination on the same day he was placed on the PIP. UiPath and Hall later entered into a Separation and Release of Claims agreement, terminating Hall's employment. Hall then joined Accelirate, Inc., but was terminated shortly after his former supervisor at UiPath informed Accelirate of complaints about Hall.The United States District Court for the Western District of Texas granted summary judgment in favor of UiPath. The court found that Hall failed to establish a causal link between his protected activity (the age discrimination complaint) and the adverse employment action (his termination). Additionally, Hall did not successfully rebut UiPath’s legitimate, non-discriminatory reason for the adverse action, which was based on Hall's performance issues.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s grant of summary judgment, noting that Hall did not challenge the district court’s determination that UiPath had provided a legitimate, non-discriminatory reason for the adverse action. Hall's failure to address this aspect of the district court’s analysis in his appeal effectively forfeited his argument. Consequently, the appellate court did not need to address the issue of causation and upheld the summary judgment in favor of UiPath. View "Hall v. UiPath" on Justia Law