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

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

Christian N. Davis, a former Army corporal, was convicted by a general court-martial in 1993 of multiple offenses, including attempted premeditated murder, conspiracy to commit murder, premeditated murder, arson, and adultery. He was sentenced to life imprisonment with the possibility of parole. After his conviction, Davis sought clemency and parole but was denied. He was later transferred to a federal civilian prison, where his parole was again denied.Davis filed a motion for compassionate release under 18 U.S.C. § 3582 in the United States District Court for the Northern District of Texas, citing his age, health conditions, low risk of recidivism, and rehabilitative efforts. The magistrate judge recommended dismissing the motion for lack of jurisdiction, as § 3582 requires such motions to be filed in the sentencing court, and Davis's sentence was imposed by a military court. The district court accepted the magistrate judge's findings, dismissed Davis's motion for compassionate release for lack of jurisdiction, and denied his habeas claims.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 held that 18 U.S.C. § 3582 does not apply to sentences imposed under the Uniform Code of Military Justice (UCMJ) and that such motions must be filed in the sentencing court. Since Davis's sentence was imposed by a general court-martial, the district court lacked jurisdiction to consider his motion for compassionate release. The court also rejected Davis's arguments based on 10 U.S.C. § 858(a) and the case Bates v. Wilkinson, concluding that neither authorized civilian courts to modify military sentences. View "Davis v. USA" on Justia Law

Two lessors, Elizabeth Franklin and Cynthia Peironnet, owned mineral interests in a tract of land in Louisiana. In 2007, Regions Bank, managing their interests, mistakenly extended a lease for the entire tract instead of a portion. Advances in drilling technology increased the tract's value, and the lessors sued Matador Resources, the lessee, to invalidate the extension. Meanwhile, they entered into a new lease with Petrohawk Energy Corporation, contingent on the invalidation of the Matador lease. The Louisiana Supreme Court upheld the Matador lease, preventing the lessors from benefiting from the more favorable Petrohawk lease.The United States District Court for the Western District of Louisiana held a bench trial in 2021, finding Regions liable for breach of contract. On remand, the court considered extrinsic evidence to determine the lease's royalty provision, concluding it should be based on gross proceeds. The court awarded damages accordingly, including prejudgment interest on past losses and discounted future losses to present value.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the lease conveyed a gross proceeds royalty and the admission of extrinsic evidence. However, it reversed the district court's award of royalty damages plus prejudgment interest. The appellate court instructed the district court to consider actual loss data for past years when recalculating damages and to award prejudgment interest from the date each item of past damages was incurred. The case was remanded for further proceedings consistent with these instructions. View "Franklin v. Regions Bank" on Justia Law

Silverthorne Seismic, L.L.C. licensed seismic data to Casillas Petroleum Resource Partners II, L.L.C. and sent the data to Sterling Seismic Services, Ltd. for processing. Silverthorne alleged that Sterling sent unlicensed data to Casillas, which Casillas then showed to potential investors. Silverthorne sued Sterling for trade-secret misappropriation under the Defend Trade Secrets Act, seeking a reasonable royalty as a remedy.The United States District Court for the Southern District of Texas set the standard for calculating a reasonable royalty, adopting a definition from a previous case, University Computing Co. v. Lykes-Youngstown Corp. The district court certified this order for interlocutory appeal under 28 U.S.C. § 1292(b), concluding that the reasonable-royalty standard was a controlling question of law with substantial ground for difference of opinion and that an immediate appeal would materially advance the litigation. The district court stayed the proceedings pending the appeal, and an administrative panel of the United States Court of Appeals for the Fifth Circuit granted leave to appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that granting leave to appeal was an error. The court found that the district court's order did not involve a controlling question of law and that the appeal would not materially advance the ultimate termination of the litigation. The court emphasized that the parties had not yet gone to trial, and Silverthorne had not proven liability, making the damages issue premature. The court vacated the order granting leave to appeal, dismissed the appeal for lack of jurisdiction, and remanded the case for further proceedings. View "Silverthorne v. Sterling Seismic" on Justia Law

Terry Pitchford was convicted of capital murder in 2006 by a Mississippi jury for his role in an armed robbery during which the store owner was killed by Pitchford’s accomplice. During jury selection, the prosecution used peremptory strikes to remove four black potential jurors. Pitchford’s counsel objected under Batson v. Kentucky, arguing racial discrimination. The trial court required the State to provide race-neutral reasons for the strikes, which it did, and the court accepted these reasons without further objection from Pitchford’s counsel.Pitchford appealed to the Mississippi Supreme Court, arguing that the State’s reasons were pretextual. The court ruled that Pitchford waived his Batson claims by not challenging the State’s race-neutral reasons during voir dire or in post-trial motions. Consequently, the court found no Batson violation and upheld the conviction and death sentence.Pitchford then filed a habeas corpus petition in the United States District Court for the Northern District of Mississippi, which granted the writ. The district court found that the state trial court failed to conduct the third step of the Batson inquiry and that Pitchford’s counsel had sufficiently objected to the State’s reasons. The court also suggested that the Mississippi Supreme Court should have considered the history of Batson violations by the prosecutor in the Flowers litigation.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court’s decision. The Fifth Circuit held that the trial court did not omit Batson’s third step and that the Mississippi Supreme Court’s decision was not contrary to or an unreasonable application of Batson. The appellate court also found that Pitchford waived his pretext argument by not raising it during voir dire and that the Mississippi courts were not required to consider the Flowers litigation. The Fifth Circuit rendered judgment dismissing Pitchford’s habeas corpus petition. View "Pitchford v. Cain" on Justia Law

Rasheed Ali Muhammad was convicted and subsequently appealed his conviction. His appeal was dismissed for want of prosecution. Muhammad then filed a 28 U.S.C. § 2255 habeas petition, which the district court denied as untimely. Later, the Fifth Circuit recalled the mandate in Muhammad’s direct appeal, reasserted jurisdiction, and affirmed the conviction after full briefing and oral argument. The Supreme Court denied certiorari and a rehearing. Muhammad then filed another § 2255 habeas petition.The United States District Court for the Southern District of Mississippi concluded that Muhammad’s new habeas petition was a “second or successive” petition under the Antiterrorism and Effective Death Penalty Act (AEDPA) and transferred it to the Fifth Circuit. The Fifth Circuit clerk denied authorization to file the petition due to procedural non-compliance. Muhammad appealed the district court’s order.The United States Court of Appeals for the Fifth Circuit reviewed de novo whether the habeas petition was “second or successive” under AEDPA. The court held that because Muhammad’s initial § 2255 petition was not adjudicated on the merits and the mandate in his direct appeal was recalled, the subsequent habeas petition was not “second or successive.” The court emphasized that the procedural history reset the count of Muhammad’s habeas petitions to zero. Consequently, the Fifth Circuit reversed the district court’s order and remanded the case for further proceedings. View "USA v. Muhammad" on Justia Law

Mark Uhlenbrock was convicted by a jury for violating 18 U.S.C. § 2261A(2)(B) by posting nude images and videos of his ex-girlfriend, YT, on Reddit, along with explicit stories written in her name. Some of the images were taken with her consent during their relationship, while others were recorded without her knowledge. Uhlenbrock's posts included personal details about YT, such as her occupation and employer, and invited men to proposition her. YT discovered the posts through a family friend and reported Uhlenbrock to the FBI.The United States District Court for the Western District of Texas denied Uhlenbrock's motion to dismiss the indictment on First Amendment and vagueness grounds. During the trial, the court allowed testimony about Uhlenbrock's prior similar conduct, which included a 2016 guilty plea for cyberstalking YT. The jury found Uhlenbrock guilty, and the district court sentenced him to 60 months in prison, three years of supervised release, and restitution. The court also revoked his supervised release from the 2016 case and sentenced him to an additional 12 months in prison. Uhlenbrock appealed both the new conviction and the revocation of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decisions. The court held that Uhlenbrock's posts constituted unprotected defamation and that the application of § 2261A(2)(B) did not violate the First Amendment. The court also found that the statute was not unconstitutionally vague and that the district court did not abuse its discretion in admitting evidence of Uhlenbrock's prior conduct. The court concluded that there was sufficient evidence for a reasonable jury to find that Uhlenbrock intended to harass or intimidate YT and that his conduct caused her substantial emotional distress. The court also rejected Uhlenbrock's claims of constructive amendment of the indictment and double jeopardy. View "USA v. Uhlenbrock" on Justia Law

Serta Simmons Bedding, LLC, an American mattress manufacturer, executed financing deals in 2016 and 2020 with various lenders. Following financial struggles exacerbated by the COVID-19 pandemic, Serta filed for bankruptcy. The 2020 financing deal, known as the "uptier" transaction, involved Serta and some lenders (Prevailing Lenders) exchanging existing debt for new super-priority debt, which was controversial and led to multiple legal disputes.The bankruptcy court in the Southern District of Texas reviewed the case. Serta and the Prevailing Lenders sought a declaratory judgment that the 2020 uptier transaction was valid under the 2016 agreement's "open market purchase" exception. The bankruptcy court granted partial summary judgment in their favor, ruling that the term "open market purchase" was unambiguous and that the 2020 uptier was valid under this exception. The Excluded Lenders and LCM Lenders, who did not participate in the uptier, appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the 2020 uptier transaction was not a permissible "open market purchase" under the 2016 agreement. The court found that an "open market purchase" refers to transactions on a specific market generally open to various buyers and sellers, such as the secondary market for syndicated loans. The 2020 uptier, conducted privately with individual lenders, did not meet this definition. The court reversed the bankruptcy court's ruling on this issue.Additionally, the court addressed the inclusion of an indemnity provision in Serta's bankruptcy reorganization plan, which aimed to protect the Prevailing Lenders from losses related to the 2020 uptier. The court found that this indemnity was an impermissible end-run around the Bankruptcy Code's disallowance of contingent claims for reimbursement and violated the Code's requirement of equal treatment for creditors. The court reversed the bankruptcy court's confirmation of the plan insofar as it included this indemnity. View "Excluded Lenders v. Serta" on Justia Law

John Gabriel Trevino, a 32-year-old man, engaged in a sexual relationship with a 14-year-old child. He was charged with production of child pornography, enticement of a minor, and possession of child pornography. Trevino pled guilty to one count of production of child pornography and was sentenced to 235 months in prison followed by 25 years of supervised release. The district court included 13 standard conditions of supervised release in the written judgment, which were not orally pronounced at sentencing.The United States District Court for the Northern District of Texas initially sentenced Trevino. Trevino appealed, arguing that the standard conditions were discretionary and should have been pronounced orally. The United States Court of Appeals for the Fifth Circuit agreed, vacated the judgment, and remanded the case to the district court to remove the unpronounced conditions. The district court issued an amended judgment omitting the standard conditions. Later, Trevino’s probation officer petitioned to reimpose the standard conditions, leading to a hearing where Trevino objected on several grounds.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in modifying the conditions of supervised release before the term began, as 18 U.S.C. § 3583(e)(2) allows such modifications. The court also found that the district court complied with the mandate rule by issuing an amended judgment and that the reimposition of the standard conditions did not violate the mandate. Additionally, the court rejected Trevino’s objections to Standard Condition No. 10, which prohibits firearm possession, finding it reasonably related to the factors in 18 U.S.C. § 3553(a) and not a greater deprivation of liberty than necessary. The court affirmed the district court’s judgment. View "U.S. v. Trevino" on Justia Law

Leon Stinson pled guilty to conspiracy to engage in bank fraud and was ordered to pay over $3.6 million in restitution. The Government sought to garnish assets, including retirement accounts solely in the name of Leon’s wife, Ellen. The district court concluded that Ellen’s accounts were marital property in which both Leon and Ellen had a “100% undivided interest” and ordered the liquidation of the accounts to satisfy the restitution order.The United States District Court for the Southern District of Mississippi denied Ellen’s motion to dismiss the writ of garnishment, asserting that Leon had no property interest in her accounts. The court held an evidentiary hearing and concluded that Ellen’s retirement accounts were marital property under Mississippi law, as defined in Hemsley v. Hemsley, and thus subject to garnishment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that under Mississippi law, property is only classified as marital property during the equitable distribution process in a divorce. Until then, a person does not have an interest in property titled solely in their spouse’s name. The court found that the district court erred in concluding that Ellen’s accounts were marital property subject to garnishment. The Fifth Circuit reversed the district court’s orders and remanded with instructions to grant Ellen’s motion to dismiss the writ of garnishment as to her retirement accounts. View "USA v. Stinson" on Justia Law