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

A Chinese manufacturer of electronic nicotine delivery systems (ENDS) sought authorization from the Food and Drug Administration (FDA) to market its refillable e-cigarette device in the United States. The device, sold without e-liquid, allows consumers to use a wide range of nicotine concentrations. The manufacturer submitted a premarket tobacco product application (PMTA) in August 2020, asserting that its product was appropriate for the protection of public health. After a preliminary assessment, the FDA identified deficiencies in the application and issued a deficiency letter in March 2023, requesting additional information. The manufacturer responded to some, but not all, of the deficiencies and requested an extension, which the FDA later denied. In January 2024, the FDA issued a final order denying the application, citing insufficient data to evaluate the product’s risks and benefits.The United States Court of Appeals for the Fifth Circuit reviewed the case after the manufacturer and a retailer based in Texas, who was also affected by the denial, petitioned for review. The court determined that venue was proper because the retailer had its principal place of business in the circuit. The petitioners argued that the FDA’s denial was arbitrary and capricious, claiming the agency failed to weigh the public health benefits of the product and improperly limited applicants to a single deficiency letter.The Fifth Circuit held that the FDA’s decision was reasonable and reasonably explained. The court found that the FDA had considered the potential benefits and risks of the product, explained the deficiencies in the application, and did not impose new evidentiary requirements without notice. The court also concluded that the FDA’s policy of issuing only one deficiency letter was adequately justified and not arbitrary. The petition for review was denied. View "Shenzhen Youme v. FDA" on Justia Law

A company specializing in supply chain services, CAM, entered into negotiations with Rockwall, a corrugated packaging manufacturer, to provide warehousing services in Louisiana. The parties discussed terms, exchanged draft contracts, and CAM ultimately leased warehouse space for three years in anticipation of a long-term arrangement. However, neither party ever executed a written contract, and CAM began providing services and invoicing Rockwall monthly. Rockwall paid these invoices for over two years, but later terminated the relationship, citing changes in its business needs.CAM filed suit in the United States District Court for the Western District of Louisiana, alleging breach of contract and detrimental reliance. The district court found that while the parties had an oral agreement for warehousing services, there was no binding contract for a fixed three-year term because both parties intended to be bound only by a written, executed agreement. The court also held that CAM’s detrimental reliance claim failed, as it was unreasonable for CAM to rely on the existence of a three-year contract term when no such term was ever agreed upon, either orally or in writing. The district court granted summary judgment in favor of Rockwall and dismissed CAM’s claims.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decision. The Fifth Circuit held that under Louisiana Civil Code article 1947, when parties contemplate a written contract, there is a presumption that they do not intend to be bound until the contract is executed in that form. The court found that this presumption was not rebutted by the parties’ conduct, including Rockwall’s payment of monthly invoices. The court also concluded that CAM failed to establish the elements of detrimental reliance, as there was no promise or representation by Rockwall of a fixed contract term. The summary judgment in favor of Rockwall was affirmed. View "CAM Logistics v. Pratt Industries" on Justia Law

A woman was stopped by a county deputy in Texas around 2:00 AM after the officer claimed to observe multiple traffic violations, including speeding and failing to maintain a single lane. The woman, who had just left a family event with her husband, denied any wrongdoing and began recording the encounter on her phone. The officer reported smelling alcohol and observing signs of intoxication, such as slurred speech and glossy eyes. The woman refused to answer certain questions or perform field sobriety tests, leading to her arrest. Body camera footage later showed her being uncooperative and verbally abusive during the arrest and subsequent blood draw at the jail. A blood test revealed a low blood alcohol content, and the criminal charge was later dismissed for insufficient evidence.The United States District Court for the Western District of Texas granted summary judgment in favor of the county and the arresting officer on all claims. The court found that the officer was entitled to qualified immunity and that there was probable cause for the arrest based on the totality of the circumstances, including the officer’s observations and the woman’s refusal to cooperate. The court also rejected claims of First Amendment retaliation, malicious prosecution, and excessive force, as well as Monell claims against the county for alleged unconstitutional policies.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s evidentiary rulings and summary judgment de novo. The appellate court affirmed the district court’s judgment, holding that the officer had probable cause to arrest for driving while intoxicated, that the woman failed to show a constitutional violation necessary for her claims, and that the county could not be held liable under Monell without an underlying constitutional violation. The court also found no abuse of discretion in the district court’s evidentiary decisions. View "Wood v. Bexar County" on Justia Law

The defendant, who had a prior Louisiana felony conviction for illegal use of a weapon stemming from a drive-by shooting in 2021, was released on parole in March 2023. One month later, he was found as a passenger in a vehicle stopped for a traffic violation, where police discovered four loaded firearms, including one reported stolen. He was charged with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) and with possessing unregistered firearms under 26 U.S.C. § 5861(d).In the United States District Court for the Western District of Louisiana, the defendant moved to dismiss both counts, arguing that the statutes were unconstitutional both facially and as applied to him. The district court denied the motion, holding that convicted felons are not protected by the Second Amendment and that the statutes align with the nation’s historical tradition of firearm regulation. The defendant then pleaded guilty to the felon-in-possession charge in exchange for dismissal of the other count, preserving his right to appeal the denial of his motion to dismiss.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the preserved as-applied constitutional challenge de novo. The court held that, under current precedent, the statute’s facial constitutionality was foreclosed. Addressing the as-applied challenge, the court found that the defendant’s prior conviction qualified as a predicate felony and that the government had identified relevant historical analogues—specifically, founding-era “going armed” laws that imposed similar burdens and justifications. The court concluded that 18 U.S.C. § 922(g)(1), as applied to the defendant, is consistent with the Second Amendment and the nation’s historical tradition of firearm regulation. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Morgan" on Justia Law

The defendant, a Mexican citizen, was first brought to the United States as a child. He was discovered by federal officials in Texas in 2015 and deported later that year. In 2020, he was again found in the United States and arrested on outstanding warrants. He was convicted in state court for drug-related offenses and sentenced to five years in prison. While serving this sentence, he was screened by immigration authorities and subsequently indicted for illegal reentry under 8 U.S.C. § 1326(a). In 2024, he pleaded guilty to the federal charge without a plea agreement. The district court sentenced him to 24 months in prison and one year of supervised release, adopting special conditions recommended in the Presentence Investigation Report (PSR), including requirements to report to immigration authorities and seek work authorization.The United States District Court for the Southern District of Texas confirmed at sentencing that the defendant and his counsel had reviewed the PSR, which contained the special conditions. The court orally adopted the PSR and its appendix, imposed the recommended conditions, and provided the defendant an opportunity to object. The defendant’s counsel objected only to the relationship between the federal and state offenses, not to the special conditions. The written judgment included all the conditions from the PSR. The defendant appealed, arguing that the written judgment conflicted with the oral pronouncement regarding the special conditions of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case for plain error, as the defendant had notice and an opportunity to object at sentencing but did not do so. The court held that the district court satisfied the oral-pronouncement requirement by adopting the PSR and providing notice and opportunity to object. Therefore, there was no conflict between the written judgment and the oral pronouncement, and the judgment of the district court was affirmed. View "USA v. Quezada-Atayde" on Justia Law

During the COVID-19 pandemic, Congress established the Paycheck Protection Program (PPP) to help eligible small businesses maintain payroll through government-mandated shutdowns. The program, administered by the Small Business Administration (SBA), provided for government-guaranteed loans to qualifying businesses, with the possibility of loan forgiveness if certain conditions were met. Bruckner Truck Sales received a $10 million PPP loan, but the SBA later determined that Bruckner was not eligible for the loan. Despite conceding its ineligibility, Bruckner refused to return the funds and instead claimed entitlement to loan forgiveness under the CARES Act.The United States District Court for the Northern District of Texas reviewed the case after Bruckner challenged the SBA’s denial of forgiveness. The district court granted summary judgment in favor of the government, holding that the CARES Act does not entitle ineligible borrowers to loan forgiveness. The court also denied Bruckner’s motion to alter or amend the judgment, finding that the SBA’s interpretation of the statute was correct and that the agency’s actions were not arbitrary or capricious.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decision. The Fifth Circuit held that the CARES Act limits loan forgiveness to borrowers who were eligible for the underlying PPP loan. The court rejected Bruckner’s arguments that the SBA’s rule was retroactive, that the agency violated the Chenery doctrine, and that the district court improperly deferred to the agency’s interpretation. The court concluded that neither the text nor the structure of the CARES Act supports forgiveness for ineligible borrowers, and affirmed the denial of loan forgiveness and the requirement to return the funds. View "Bruckner Truck Sales v. Guzman" on Justia Law

A woman brought suit against the United States under the Federal Tort Claims Act (FTCA) after her child suffered severe and permanent nerve damage during childbirth at a Texas hospital. She alleged that the resident physician who delivered her baby used excessive force in responding to a complication known as shoulder dystocia, and that the attending physician failed to properly supervise. The plaintiff sought compensatory damages for medical care and related expenses.The United States District Court for the Western District of Texas dismissed the case for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). The district court, adopting a magistrate judge’s recommendation, determined that shoulder dystocia is always an obstetrical emergency under Texas law. It concluded that, in such emergencies, Texas law requires proof of “willful and wanton negligence” (a heightened standard akin to gross negligence). The court further reasoned that because the FTCA does not waive sovereign immunity for punitive damages, and because damages for willful and wanton negligence are punitive, it lacked jurisdiction to hear the case.On appeal, the United States Court of Appeals for the Fifth Circuit reversed and remanded. The Fifth Circuit held that the district court erred in two respects: first, by presuming as a matter of law that the physician provided emergency medical care in every instance of shoulder dystocia, rather than treating it as a factual question; and second, by conflating the heightened standard of liability (willful and wanton negligence) with the nature of damages recoverable. The Fifth Circuit clarified that compensatory damages for gross negligence are available under Texas law and are not barred by the FTCA, which only precludes punitive damages. The case was remanded for further proceedings. View "Robledo v. USA" on Justia Law

Donald Wright was employed by Honeywell International for fourteen years as a Dock B Operator. In 2021, Honeywell instituted a mandatory COVID-19 vaccination policy in response to a federal executive order affecting federal contractors. Wright, a Baptist Christian, requested a religious exemption from the policy, citing his belief in God-given bodily autonomy and referencing certain scriptural passages. He also submitted a third-party attestation from his daughter, who explained their shared religious beliefs. Honeywell denied his exemption request, stating that Wright had not adequately identified a sincerely held religious belief prohibiting vaccination. Wright was subsequently suspended and then terminated for failing to comply with the vaccination requirement.Wright filed a charge of discrimination with the Equal Employment Opportunity Commission and, after receiving a right-to-sue letter, brought suit in the United States District Court for the Middle District of Louisiana. He alleged religious discrimination and disparate treatment under Title VII. The district court granted summary judgment in favor of Honeywell on all claims, finding that Wright had not provided sufficient evidence to raise a genuine issue of material fact regarding the existence of a bona fide religious belief or that he had informed Honeywell of such a belief. Wright’s motion for reconsideration was denied, and he appealed, but only as to the religious discrimination claim.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment decision de novo. The Fifth Circuit held that Wright had presented sufficient evidence to create a genuine dispute of material fact as to whether he held a bona fide religious belief and whether he informed Honeywell of that belief. The court reversed the district court’s grant of summary judgment on the Title VII religious discrimination claim and remanded the case for further proceedings. The court did not address the disparate treatment claim or the motion for reconsideration, as those issues were either not appealed or rendered moot. View "Wright v. Honeywell International" on Justia Law

Texas enacted a law in 2021 requiring voters who wish to vote by mail to provide an identification number—such as a driver’s license or the last four digits of their Social Security number—on both their mail-in ballot applications and the ballots themselves. This number must match the one provided during voter registration. If the numbers do not match or are missing, the application or ballot is rejected. The law was challenged by the United States and several private plaintiffs, who argued that these requirements violate the materiality provision of the Civil Rights Act of 1964, which prohibits denying the right to vote due to errors or omissions on paperwork if those errors are not material to determining voter qualification.The United States District Court for the Western District of Texas consolidated the lawsuits and denied Texas’s motion to dismiss, finding that the plaintiffs had standing and that sovereign immunity did not bar the private plaintiffs’ claims. After discovery, the district court granted summary judgment for the plaintiffs, holding that the identification number requirement was not material to voter eligibility and enjoined Texas from enforcing the number-matching provisions.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the district court lacked jurisdiction over the private plaintiffs’ claims against the Secretary of State due to a pending appeal on sovereign immunity, but found no jurisdictional bar to reviewing the United States’ claims. The Fifth Circuit held that the identification number requirement is material to determining whether an individual is qualified to vote under Texas law, as it serves to confirm the voter’s identity and prevent fraud. The court concluded that the law complies with the materiality provision of the Civil Rights Act and reversed the district court’s judgment, rendering judgment for the defendants. View "USA v. Paxton" on Justia Law

Three registered Texas voters alleged that three local officials—a justice of the peace, a sheriff, and a constable—conspired to punish them for political reasons. The plaintiffs were arrested after reporting for jury duty, accused of falsely claiming residency in Loving County. The officials argued they were enforcing voter-eligibility rules, while the plaintiffs claimed it was retaliation to silence dissent. The plaintiffs sued under § 1983, alleging constitutional violations.The United States District Court for the Western District of Texas granted judicial and quasi-judicial immunity to the officials for some claims but denied judicial immunity for actions related to the jury proceeding. The officials appealed the denial of judicial immunity, and the plaintiffs cross-appealed the grant of immunity on other claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that presiding over the jury proceeding was a judicial act protected by absolute judicial immunity. Consequently, the court reversed the district court's denial of judicial immunity for the jury proceeding. Regarding the plaintiffs' cross-appeal, the court found it lacked jurisdiction to review those claims at this interlocutory stage and dismissed the cross-appeal.The court's main holding was that the actions of the justice of the peace in presiding over the jury proceeding were judicial in nature and thus protected by absolute judicial immunity. The court reversed the district court's decision in part and dismissed the cross-appeal for lack of jurisdiction. View "Jones v. King" on Justia Law