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

Plaintiff sued her siblings based on diversity jurisdiction, alleging that the siblings, co-trustees of the Brunsting Family Living Trust, had breached their fiduciary duties to her, a beneficiary of the trust. At issue was the scope of the probate exception to federal subject matter jurisdiction in the wake of the Supreme Court's decision in Marshall v. Marshall. The court found no evidence that the trust was subject to the ongoing probate proceedings and concluded that the case fell outside the scope of the probate exception. Therefore, the district court erred in dismissing the case for lack of subject matter jurisdiction. View "Curtis v. Brunsting, et al" on Justia Law

Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Louisiana state court denied petitioner's application for a writ of habeas corpus. The federal district court subsequently granted habeas relief, determining that the state court's decision was based on an unreasonable determination of the facts. Petitioner claimed that he received ineffective assistance of counsel because his counsel did not investigate and interview alibi witnesses who would have testified that petitioner had not shot the victim. The court concluded that the state court's finding that petitioner's counsel interviewed alibi witnesses was not an unreasonable determination of the facts. Therefore, it was error to conclude as the district court did that there was no reasonable argument that counsel's performance was satisfactory. The court did not need to reach the issue of prejudice. Accordingly, the court affirmed the judgment. View "Kately v. Cain" on Justia Law

Plaintiff sued the school district alleging that the district's decision to hire a Caucasian woman in lieu of promoting him amounted to race discrimination in violation of Title VII. The district court granted summary judgment to the district and ordered plaintiff to pay attorneys' fees. The court found no competent evidence from which a reasonable juror could infer that the district's decision to hire the woman in lieu of promoting plaintiff was motivated by impermissible racial considerations. The court held, however, that the district court's fee award constituted an abuse of discretion where the court did not agree that plaintiff's claim was frivolous, unreasonable, or without foundation. View "Autry v. Fort Bend Independent Sch. Dist." on Justia Law

A third-party administrator of medical benefits plans, IMA, denied claims made on behalf of two patients who received treatment from the same medical provider, LifeCare. The court held that IMA incorrectly interpreted the plans because it categorized LifeCare as a skilled nursing facility (SNF) without finding that LifeCare "fully meets all of" the plans' seven SNF factors. IMA abused its discretion because categorizing LifeCare as an SNF without considering the seven-factors SNF test contradicted the plain language of the plans. The court found that the district court correctly held that LifeCare could maintain an action against IMA pursuant to 29 U.S.C. 1132(a)(1)(B) and that IMA was liable for exercising actual control over the claims process. The court further held that the district court did not abuse its discretion in awarding attorneys' fees. View "Lifecare Mgmt. Svcs., LLC v. Ins. Mgmt. Admins. Inc, et al" on Justia Law

Defendant appealed his conviction and sentence for conspiracy to possess with intent to distribute more than five kilograms of cocaine. On appeal, defendant contended that the district court erred in denying his motion to suppress evidence and in applying a two-point sentencing enhancement for use of a minor to commit his crime. Because the officer's continued search and seizure beyond the scope of the initial traffic stop were justified by additional reasonable suspicion, the district court did not err in concluding that the scope of the stop was reasonable. Because the court found that the district court did not err in refusing to suppress the drug evidence, the court did not reach the remaining plain error factors. The court also concluded that the district court did not err in applying the U.S.S.G. 3B1.4 enhancement where defendant's choice to drive a truck containing over twenty kilograms of cocaine and a four-year-old girl from Laredo to Chicago constituted an "affirmative act" involving a minor in the offense. Accordingly, the court affirmed the judgment. View "United States v. Andres" on Justia Law

Defendant was found guilty of failing to comply with his registration requirement in violation of the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16913(a). On appeal, defendant argued that the district court's instruction to the jury erroneously defined the term "resides," and constituted harmful error. Because the district court's instruction was not inconsistent with SORNA and because defendant failed to allege the instruction misstated the Sentencing Guidelines, the court found no reversible error in the district court's instruction and affirmed the conviction. View "United States v. Wampler" on Justia Law

Albemarle challenged an arbitrator's award in a labor dispute after Albemarle terminated two employees for violating its safety protocols and the employees' union, USW, filed a grievance. Albemarle first contended that the arbitrator's finding of "cause for the Employer to issue discipline," left no choice under the collective bargaining agreement (CBA) but to affirm its decision to terminate the employees. Second, Albemarle maintained that the award was unenforceable as a violation of public policy. The court concluded that because the arbitrator's award neither violated the terms of the CBA nor public policy, the court must enforce it. Accordingly, the court reversed the award of summary judgment in favor of Albermarle and rendered judgment in favor of USW. View "Albemarle Corp. v. United Steel Workers, Local 103" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the school district, alleging that she was denied a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that plaintiff satisfied the court's liberal notice of appeal requirements and therefore considered the appeal on the merits. The court found that the district court complied with the IDEA's procedural requirements and, moreover, if any defects existed, they did not rise to the level of denying plaintiff a lost educational opportunity. In regards to plaintiff's substantive claim, the court analyzed the Michael F. factors and concluded that plaintiff received a FAPE. Accordingly, the court affirmed the judgment. View "R. P. v. Alamo Heights Indep Sch Dist" on Justia Law

Homeowners, who were represented by the Mostyn Law Firm, filed claims against State Farm in Texas state court after Hurricane Ike. State Farm removed several cases to federal court on diversity grounds. The Firm and State Farm then entered into an agreement whereby the Firm promised to abandon its clients' claims against individual adjusters and forgo suing them in the future in exchange for State Farm's promise not to remove any Hurricane Ike cases to federal court. At issue on appeal was whether the phrase "any Hurricane Ike cases," in a contract covering "all Hurricane Ike cases that either have been filed or will be filed in the future," encompassed class-action lawsuits. The court affirmed and agreed with the district court's conclusion that the negotiated contract covered all past, present, and future lawsuits filed by the Firm against State Farm on behalf of homeowners, as individuals or part of a class, whose properties were damaged during Hurricane Ike. View "Horn, et al v. State Farm Lloyds" on Justia Law

Defendants appealed the denial of their motion for summary judgment based on qualified immunity from plaintiff's 42 U.S.C. 1983 excessive-force and state-law claims. The district court denied summary judgment, concluding that there were issues of material fact as to whether the force used by the officers was clearly excessive and objectively unreasonable. Under the applicable law, the court had no jurisdiction to review a district court's determination that there were genuine disputes of fact where the court had decided, as a matter of law, that those factual issues were material. Therefore, the court affirmed the judgment of the district court and dismissed the appeal. View "Newman v. Guedry, et al" on Justia Law