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

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

Capstone Logistics, LLC, a company providing labor to other businesses, began supplying auditors to Associated Wholesale Grocers in 2019. The auditors, including Joyce Henson, were responsible for checking groceries and ensuring order accuracy. Henson, hired as lead auditor, raised concerns about safety, training, and pay on behalf of the auditors. She also contacted Donny Rouse, a major customer, about her pay. After a meeting with Capstone officials, Henson sent a LinkedIn message to Rouse about the auditors' pay issues. Following a brief interaction with Associated Wholesale Grocers' Director Chris Griffin, Henson was terminated by Capstone's Vice President Tim Casey.The National Labor Relations Board (NLRB) issued a complaint against Capstone, alleging violations of the National Labor Relations Act (NLRA) for discharging Henson due to her protected concerted activities. An administrative law judge (ALJ) dismissed the allegations, finding no sufficient causal connection between Henson's protected activities and her termination. The ALJ concluded that Henson's termination was more likely due to her efforts to secure better compensation for herself.The NLRB reversed the ALJ's decision, finding that Henson was discharged for engaging in protected concerted activity by sending the LinkedIn message to Rouse and because Capstone believed she had engaged in such activity during her conversation with Griffin. Capstone petitioned for review, and the NLRB cross-petitioned for enforcement of its order.The United States Court of Appeals for the Fifth Circuit found insufficient evidence to support the NLRB's finding that Capstone discharged Henson for sending the LinkedIn message. However, the court affirmed the NLRB's alternative determination that Capstone violated Section 8(a)(1) of the NLRA by discharging Henson because it believed she had engaged in protected concerted activity. The court denied Capstone's petition for review and granted the NLRB's cross-application to enforce its order. View "Capstone Logistics v. National Labor Relations Board" on Justia Law

Taiwo Ayorinde sued his former employer, Team Industrial Services Incorporated, alleging various employment discrimination claims. Ayorinde was initially employed by Team from 2016 to 2018 and rehired in 2022. During his second tenure, his supervisor expressed concerns about his work quality and demoted him, resulting in a pay cut. While on bereavement leave, Ayorinde discovered the pay cut, which was later reversed by Team. Ayorinde resigned, citing a hostile work environment and discrimination, and subsequently filed a discrimination charge with the EEOC.The United States District Court for the Western District of Texas granted summary judgment in favor of Team on all claims and denied Ayorinde’s motion for partial summary judgment. The court found that Ayorinde failed to establish a prima facie case for his claims, including race discrimination, retaliation, constructive discharge, and hostile work environment. Ayorinde appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Ayorinde did not provide sufficient evidence to support his claims. Specifically, Ayorinde failed to show that he was treated less favorably than similarly situated employees outside his protected group, which is necessary to establish a prima facie case of race discrimination. Additionally, the court found no evidence of retaliatory adverse employment action based on protected activity, and Ayorinde did not exhaust his administrative remedies regarding his constructive discharge and hostile work environment claims. The court also noted that Ayorinde abandoned his claims under the Lilly Ledbetter Fair Pay Act and the Age Discrimination in Employment Act by not adequately briefing them on appeal. View "Ayorinde v. Team Industrial" on Justia Law

A union representing over 9,000 pilots employed by an airline alleged that the airline violated the Railway Labor Act (RLA) by intimidating and disciplining pilots who affiliated with the union. The union claimed that the airline had a history of isolating a special category of pilots known as "check pilots" and "standards check pilots," who are responsible for training and evaluating other pilots. The union alleged that the airline unilaterally established working conditions for check pilots without bargaining and that check pilots were threatened with losing their qualifications if they affiliated with the union. The union also claimed that the airline retaliated against a pilot, Captain Timothy Roebling, by stripping him of his check-pilot qualifications after he joined a union committee.The United States District Court for the Northern District of Texas dismissed the union's complaint, concluding that the dispute was subject to arbitration under the RLA and that no exception applied to vest the court with jurisdiction. The district court found that the airline had an arguable basis for its actions under the collective bargaining agreement, making the dispute a "minor" one subject to arbitration.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the union had sufficiently pleaded the anti-union animus exception to the RLA's arbitration requirement. The court found that the union's allegations, including threats and retaliatory actions against check pilots, supported the claim that the airline's actions were intended to weaken or destroy the union. The court reversed the district court's dismissal and remanded the case for further proceedings, holding that the union's complaint sufficiently alleged anti-union animus to warrant judicial intervention. View "Southwest Airlines Pilots Assn v. Southwest Airlines" on Justia Law