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

Aramark, a company that self-funds employee health benefit plans governed by ERISA, contracted with Aetna to serve as third-party administrator for these plans. Under the agreement, Aetna was responsible for processing claims, managing provider networks, and handling various administrative tasks. Aramark alleged that Aetna breached its fiduciary duties by paying improper or fraudulent claims, retaining undisclosed fees, providing inadequate subrogation services, making post-adjudication adjustments detrimental to Aramark, and commingling plan assets.Aramark filed suit in the United States District Court for the Eastern District of Texas, asserting ERISA claims for breach of fiduciary duty and prohibited transactions. Aetna responded by seeking to compel arbitration in a Connecticut federal district court, relying on the arbitration clause in the parties’ Master Services Agreement (MSA), and moved to stay the Texas proceedings pending arbitration. The district court denied the stay, holding that the parties had not “clearly and unmistakably” delegated the threshold question of arbitrability to an arbitrator. The court found that the MSA's arbitration clause carved out disputes seeking equitable relief—such as Aramark’s ERISA claims—from arbitration and that these claims were equitable in nature.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of a motion to stay litigation pending arbitration de novo. It held that the threshold issue of arbitrability was not clearly and unmistakably delegated to an arbitrator under the terms of the MSA, especially given the placement of the carve-out for equitable relief. The Fifth Circuit further held that Aramark’s ERISA claims constituted equitable, not legal, relief under Supreme Court and Fifth Circuit precedent. The Fifth Circuit affirmed the district court’s orders, finding no error or abuse of discretion. View "Aramark Services v. Aetna Life Insurance" on Justia Law

A former professional football player sought disability benefits from a retirement plan administered under the Employee Retirement Income Security Act (ERISA), arguing that he qualified for the highest tier of benefits due to multiple concussions suffered during his career. The plan granted him some benefits but denied the top category. He filed suit, claiming improper denial of benefits and lack of a full and fair review.The United States District Court for the Northern District of Texas ruled in favor of the plaintiff, ordering the plan to award the higher benefits and granting approximately $1.2 million in attorney’s fees, plus $600,000 in conditional fees. On appeal, however, a panel of the United States Court of Appeals for the Fifth Circuit reversed the district court’s judgment, holding that the plaintiff was not entitled to reclassification to the highest benefits tier due to his failure to immediately appeal the denial, making any further review futile. The panel remanded for entry of judgment for the plan.On remand, the district court nonetheless reaffirmed its prior fee award, reasoning that the plaintiff’s success in exposing flaws in the plan’s review process, as reflected in favorable factual findings, constituted sufficient success to support attorney’s fees.The United States Court of Appeals for the Fifth Circuit, reviewing the fee award for abuse of discretion, reversed the district court’s decision. The Fifth Circuit held that under 29 U.S.C. § 1132(g)(1), attorney’s fees may only be awarded if a party achieves “some degree of success on the merits,” which requires more than favorable factual findings or moral victories. Because the plaintiff received no relief—monetary, injunctive, or declaratory—the award of attorney’s fees was improper. The court reversed the fee award. View "Cloud v. NFL Player Retirement Plan" on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

Hiran Management, a small karaoke restaurant in Houston, Texas, employed eight front-of-house workers who became dissatisfied with their manager’s practices, including being assigned extra duties without increased pay and inconsistent compensation for “shift supervisor” roles. After a contentious meeting with management, the employees walked out, went on strike, and presented a list of demands. The employer subsequently terminated all eight striking employees.Following these terminations, the National Labor Relations Board (NLRB) filed an administrative complaint, alleging that Hiran Management violated section 8(a)(1) of the National Labor Relations Act (NLRA) by firing the employees for engaging in protected concerted activity. An administrative law judge (ALJ) ruled in favor of the NLRB, and the Board adopted the ALJ’s findings with minor adjustments. The Board ordered Hiran to cease its unfair labor practices, reinstate the employees, and compensate them for lost earnings and all other direct or foreseeable pecuniary harms resulting from the terminations.Hiran Management petitioned the United States Court of Appeals for the Fifth Circuit for review, while the NLRB sought enforcement of its order. The Fifth Circuit held that the NLRB lacks statutory authority under the NLRA to award full compensatory damages for all direct or foreseeable pecuniary harms, as such damages are legal rather than equitable remedies. The court granted Hiran’s petition in part, denied the NLRB’s enforcement petition in part, and remanded the case for further proceedings consistent with its opinion, limiting the NLRB’s remedial authority to equitable relief such as reinstatement and backpay. View "Hiran Management v. National Labor Relations Board" on Justia Law

Felicia Scroggins, a pro se plaintiff, brought claims against the City of Shreveport alleging race and sex discrimination, as well as retaliation, under Title VII. Her allegations included being incorrectly reprimanded for a safety incident, being compelled to undergo a fit-for-duty evaluation, and being disciplined for backing a fire engine into a fence. She also challenged the fairness of the bidding procedures for job assignments, claiming they were applied to her in a discriminatory manner.The United States District Court for the Western District of Louisiana reviewed the case. After Scroggins’s counsel withdrew, the district court granted her several extensions to find new counsel before ruling on the City’s motion for summary judgment. Ultimately, the district court granted summary judgment in favor of the City, finding that Scroggins failed to produce competent summary judgment evidence of pretext for her retaliation claims and that, although she established a prima facie case of discrimination, the City provided legitimate, nondiscriminatory reasons for its actions which she did not rebut.On appeal, the United States Court of Appeals for the Fifth Circuit considered Scroggins’s arguments that the district court erred by granting summary judgment before she could secure new counsel and by inadequately analyzing her claims under the McDonnell Douglas framework. The Fifth Circuit held that Scroggins forfeited her arguments by failing to cite relevant authority and failing to point to evidence in the record to support her claims. The court also found that the district court properly assumed adverse employment actions for purposes of the retaliation claims and correctly applied the McDonnell Douglas test to both discrimination and retaliation claims. The Fifth Circuit affirmed the district court’s grant of summary judgment in favor of the City. View "Scroggins v. City of Shreveport" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

A correctional officer employed by the Texas Department of Criminal Justice (TDCJ) for 18 years suffered from diabetes, hypertension, and chronic back pain. She took intermittent leave under TDCJ’s leave-without-pay (LWOP) policy, which allowed up to 180 days of leave in a rolling 12-month period. After returning from leave in 2017, she was reassigned to a less desirable shift without explanation, leading her to file internal grievances and an equal employment opportunity (EEO) complaint. Although her grievance was sustained and she was returned to her preferred shift, subsequent confusion over her LWOP balance resulted in her termination in 2018. She later reapplied for her job but was not rehired, despite recommendations in her favor and a shortage of correctional officers.The United States District Court for the Eastern District of Texas heard her claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. After a jury trial, she prevailed on all counts, receiving $1.8 million in damages, which the district court reduced to $1 million after excluding emotional distress damages per Supreme Court precedent. The court denied the defendants’ motions for judgment as a matter of law and for a new trial, entering final judgment for the plaintiff and awarding attorney’s fees and costs.On appeal, the United States Court of Appeals for the Fifth Circuit held that monetary relief against the executive director under the ADA was barred by sovereign immunity and reversed that portion of the judgment. The court affirmed the jury’s findings on discrimination and retaliation under the Rehabilitation Act against TDCJ, but found the $1 million damages award included amounts that should have been considered front pay, not back pay, and remanded for recalculation. The court also vacated the attorney’s fee award against the executive director and remanded for reconsideration of fees against TDCJ. The judgment was affirmed in part, reversed in part, vacated, and remanded. View "Harmon v. Collier" on Justia Law

A group of former employees, most of whom are Black, brought claims against their former employer, an IT company, and its parent corporation. They alleged race discrimination, a hostile work environment, and retaliation for opposing discrimination, citing actions such as terminations, denials of promotions, and workplace policies they believed targeted Black employees. The plaintiffs described being subjected to stricter rules, surveillance, and less favorable treatment compared to non-Black employees. One plaintiff, who is white, also alleged retaliation for supporting his Black colleagues.The United States District Court for the Eastern District of Texas granted summary judgment to the employer on all hostile work environment claims and on certain discrimination and retaliation claims, finding insufficient evidence of an “ultimate employment decision” as required by then-controlling precedent. The court also excluded some witness testimony. At trial, a jury found for nine plaintiffs on discrimination and retaliation claims, awarding substantial damages. However, the district court granted judgment as a matter of law (JMOL) to the employer on most claims, finding insufficient evidence to support the jury’s verdicts, and to the parent company, concluding it was not an “integrated enterprise” with the employer. The court also granted a new trial on two retaliation claims, finding the verdicts contrary to the weight of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case. It vacated the summary judgment on certain discrimination and retaliation claims, remanding those for further proceedings in light of new precedent that broadened the definition of adverse employment actions. The Fifth Circuit affirmed the district court’s rulings in all other respects, including the grants of JMOL, the new trial orders, the exclusion of witness testimony, and the finding that the parent company was not liable as an integrated enterprise. View "Yarbrough v. SlashSupport" on Justia Law

An employee at a meatpacking plant in Texas died after contracting COVID-19, allegedly from a coworker who continued working after testing positive. The decedent’s family sued the plant manager, the safety manager, and the coworker in Texas state court, claiming negligence and gross negligence due to unsafe working conditions and inadequate precautions against COVID-19. The complaint alleged that the employer, Tyson Foods, failed to protect employees, and that the managers were responsible for workplace safety. The coworker was accused of coming to work and failing to take precautions after testing positive.The defendants removed the case to the United States District Court for the Eastern District of Texas, arguing that the Texas-based managers were improperly joined to defeat diversity jurisdiction. The district court agreed, dismissed the claims against the managers with prejudice, and denied the plaintiffs’ motion to remand. Tyson Foods was later added as a defendant. The district court then dismissed the claims against Tyson on the grounds that they were preempted by the Poultry Products Inspection Act (PPIA), and dismissed the claims against the coworker for failure to state a claim, finding no individual duty to prevent the spread of disease under Texas law. The court denied leave to amend the complaint as futile and entered final judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s denial of the motion to remand and the dismissal of the coworker, holding that the managers were improperly joined and that Texas law does not impose an individual duty on coworkers to prevent the spread of disease. However, the Fifth Circuit reversed the dismissal of the claims against Tyson, holding that the PPIA does not preempt state law negligence claims based on workplace safety unrelated to food adulteration. The court vacated the denial of leave to amend and remanded for further proceedings. View "Williams v. Wingrove" on Justia Law

A white male lieutenant who had worked for the Louisiana State Police since 1995 applied for promotion to captain 31 times between 2008 and 2021 but was never selected. He alleged that, on at least two occasions, he was the most qualified candidate but was passed over in favor of non-white applicants. The two specific promotions at issue involved positions in specialized divisions where the selected candidates, both non-white, had prior experience in those divisions, while the plaintiff did not. The plaintiff claimed he had higher test scores, more time in grade, and more commendations than the selected candidates. Instead of promotion, he was offered opportunities to gain broader experience and interview advice, but he chose to retire and then filed suit alleging racial discrimination under Title VII and 42 U.S.C. § 1981, as well as constructive discharge and retaliation.The United States District Court for the Eastern District of Louisiana dismissed the § 1981, constructive discharge, and retaliation claims, finding the § 1981 claim time-barred by Louisiana’s one-year statute of limitations for such actions. After discovery, the district court granted summary judgment to the employer on the Title VII claim, holding that the plaintiff failed to rebut the employer’s legitimate, nondiscriminatory reasons for its promotion decisions—namely, the selected candidates’ relevant experience in the specific divisions. The court found no evidence that race was a motivating factor in the decisions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the district court’s rulings. The Fifth Circuit held that the plaintiff failed to present evidence sufficient to create a genuine dispute of material fact regarding pretext or mixed-motive discrimination under Title VII. The court also affirmed the dismissal of the § 1981 claim, agreeing that the one-year limitations period applied because the promotion would have created a new and distinct employment relationship. View "Stelly v. Dept of Public Safety" on Justia Law