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

An ordained minister served as Executive Director of a regional Baptist convention, where he was responsible for implementing a joint ministry agreement with a national Baptist mission board. Disagreements arose between the minister and the mission board regarding the execution of their shared evangelical objectives, particularly concerning missionary selection, funding, and work requirements. The mission board expressed dissatisfaction with the minister’s leadership and gave notice to terminate the partnership agreement. Subsequently, the regional convention’s board unanimously voted to terminate the minister’s employment, citing concerns about his leadership and spiritual disposition. After his termination, the minister publicly criticized the mission board and its president, which led to further actions by the board, including security measures and the posting of a no-entry photograph of the minister at its headquarters.The minister filed suit in Mississippi state court against the mission board, alleging tortious interference with business relationships, defamation, and intentional infliction of emotional distress. The mission board removed the case to the United States District Court for the Northern District of Mississippi and moved to dismiss, arguing that the church autonomy doctrine barred the claims. The district court initially denied the motion to dismiss but later granted summary judgment for the mission board, concluding that the First Amendment’s church autonomy doctrine precluded adjudication of the minister’s claims. On appeal, the United States Court of Appeals for the Fifth Circuit previously reversed and remanded, finding it premature to apply the doctrine at an early stage. After further discovery, the district court again granted summary judgment for the mission board on church autonomy grounds.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the church autonomy doctrine, rooted in the First Amendment, bars civil courts from adjudicating employment-related claims that would require inquiry into religious doctrine, internal management, or ministerial decisions. The court concluded that all of the minister’s claims were precluded by this doctrine, regardless of the organizational structure of the Baptist entities involved. View "McRaney v. N Amer Mission Bd" on Justia Law

A dispute arose over the ownership of real property located at 829 Yale Street in Houston, Texas. In 2019, Nicholas Fugedi, acting as trustee for the Carb Pura Vida Trust, initiated a quiet title action against several defendants. The central issue became whether the trust, and specifically Fugedi’s appointment as trustee, was used as a device to create diversity jurisdiction in federal court, given that Fugedi was a citizen of Michigan while the underlying parties were Texas residents.Initially, the United States District Court for the Southern District of Texas ruled against Fugedi, finding the deed void under Texas law. On appeal, the United States Court of Appeals for the Fifth Circuit reversed that decision but noted that the district court could consider new evidence on remand regarding whether the trust was a sham created to manufacture diversity jurisdiction. On remand, the district court found that Fugedi had been appointed as a sham trustee solely to create diversity jurisdiction, and dismissed the case for lack of subject matter jurisdiction under 28 U.S.C. § 1359.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo, and its factual findings for clear error. The Fifth Circuit held that 28 U.S.C. § 1359 applies to trusts and that a trust can be used as a device to improperly manufacture diversity jurisdiction. The court found no clear error in the district court’s factual findings that Fugedi was appointed as a sham trustee for the purpose of creating federal jurisdiction. Accordingly, the Fifth Circuit affirmed the district court’s dismissal for lack of subject matter jurisdiction. View "Fugedi v. Initram" on Justia Law

Two former officers and directors of a Texas community bank faced regulatory action after the bank failed in 2013 following significant losses during the 2008 financial crisis. The Office of the Comptroller of the Currency (OCC) alleged that the individuals engaged in unsafe and unsound banking practices, breached fiduciary duties, and filed materially inaccurate reports. The OCC’s claims centered on three main strategies: the bank’s practice of making loans to finance purchases of its holding company’s stock (which were then counted as capital), aggressive and risky sales of real estate owned by the bank, and improper accounting for nonaccrual loans. These actions allegedly overstated the bank’s capital and masked its true financial condition, ultimately resulting in substantial losses.After the OCC initiated an enforcement action in 2017, the matter was reassigned to a new Administrative Law Judge (ALJ) following the Supreme Court’s decision in Lucia v. SEC. The new ALJ ratified prior rulings, conducted a hearing, and issued a recommendation. The Comptroller adopted most of the ALJ’s findings but imposed industry bans and civil penalties on both petitioners, concluding that their conduct warranted prohibition from banking and monetary sanctions. The petitioners then sought review from the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit denied the petition for review. The court held that the OCC’s enforcement action fell within the public rights doctrine, so the petitioners were not entitled to a jury trial under the Seventh Amendment. The court also found that the ALJ’s appointment was constitutionally valid, the enforcement action was timely under the applicable statute of limitations, and the agency’s evidentiary and procedural rulings were supported by substantial evidence. The court further upheld the Comptroller’s decision to impose prohibition orders and civil penalties, finding the preponderance of the evidence standard appropriate for such administrative proceedings. View "Ortega v. Office of the Comptroller of the Currency" on Justia Law

A native of Uzbekistan and citizen of Israel entered the United States on a visitor’s visa in 2009, married a U.S. citizen, and had two children who are U.S. citizens. After his visa expired, he was placed in removal proceedings, conceded removability, and was ordered removed. He sought to adjust his status based on marriage, but after divorcing in 2017, that petition was withdrawn. He then applied for cancellation of removal on two grounds: (1) that his removal would cause exceptional and extremely unusual hardship to his U.S. citizen children, and (2) that he was eligible for special cancellation under the Violence Against Women Act (VAWA) due to alleged battery or extreme cruelty by his ex-wife.An Immigration Judge (IJ) denied both applications, finding his testimony credible but insufficient without corroborating evidence such as medical records for his daughter, proof of child support payments, or tax returns. The IJ also found that his ex-wife’s conduct did not rise to the level of battery or extreme cruelty required by statute. The Board of Immigration Appeals (BIA) affirmed, agreeing that the evidence did not meet the statutory standards for either form of relief and that the lack of corroboration was fatal to his claims.The United States Court of Appeals for the Fifth Circuit reviewed the BIA’s decision. The court held that it had jurisdiction to review the application of legal standards to established facts as mixed questions of law and fact. The court concluded that the BIA correctly determined the petitioner failed to provide required corroborating evidence for hardship and that the ex-wife’s actions did not constitute battery or extreme cruelty under the statute. The petition for review was denied. View "Simantov v. Bondi" on Justia Law

Luis Alfredo Lezama-Ramirez, a noncitizen who had previously been removed from the United States, pleaded guilty to unlawfully reentering the country in violation of federal law. After his guilty plea, the Probation Office prepared a presentence report (PSR) that included a list of standard and special conditions for supervised release. At sentencing, Lezama-Ramirez’s counsel indicated there were no objections to the PSR, and the district court adopted it. The court imposed a one-year term of supervised release, referencing compliance with standard and special conditions, but did not read these conditions aloud. The written judgment later included the same conditions as those in the PSR.The United States District Court for the Eastern District of Louisiana entered the judgment, and Lezama-Ramirez appealed, arguing that there were discrepancies between the oral pronouncement of supervised release conditions at sentencing and those listed in the written judgment. He specifically challenged the imposition of certain standard and special conditions that were not read aloud, as well as differences between the oral and written versions of two particular conditions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that because Lezama-Ramirez had notice of the supervised release conditions through the PSR and did not object at sentencing, there was no reversible error in imposing the conditions that were not read aloud. However, the court found that the written version of one special condition (Special Condition 2) imposed an additional reporting requirement not included in the oral pronouncement, which constituted an impermissible conflict. The Fifth Circuit vacated the imposition of Special Condition 2 and remanded for the district court to conform it to the oral pronouncement, while affirming the remainder of the judgment. View "United States v. Lezama-Ramirez" on Justia Law

The defendant pleaded guilty to possessing a firearm after a felony conviction, in violation of 18 U.S.C. § 922(g)(1). The presentence investigation report determined that the defendant’s offense level was increased due to two prior Louisiana felony convictions: aggravated battery and distribution of cocaine. The report also applied enhancements for a stolen firearm and use of the firearm in connection with another felony. The defendant objected to these enhancements and the classification of his prior aggravated battery conviction as a “crime of violence.” The district court overruled the objections, adopted the report’s findings, and sentenced the defendant to 120 months in prison, the statutory maximum.On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant argued that § 922(g)(1) is unconstitutional under the Second Amendment, relying on New York State Rifle & Pistol Ass’n, Inc. v. Bruen, and that the district court erred in treating his prior aggravated battery conviction as a crime of violence for sentencing purposes. The defendant had not raised these arguments in the district court, so the Fifth Circuit reviewed for plain error.The Fifth Circuit held that, under existing precedent, a conviction under § 922(g)(1) does not constitute plain error, and there has been no development in the law to suggest otherwise. Regarding the sentencing enhancement, the court found that the defendant failed to show a “realistic probability” that Louisiana courts would uphold an aggravated battery conviction based on reckless or negligent conduct, as required to demonstrate clear or obvious error under the categorical approach. The court concluded that neither the conviction nor the sentence was reversible under plain error review and affirmed the judgment of the district court. View "USA v. Sereal" on Justia Law

Fieldwood Energy LLC, an oil and gas company, contracted with Island Operating Company, Inc. (IOC) through a Master Services Contract (MSC) to provide workers for oil and gas production services on offshore platforms in the Gulf of Mexico. The MSC defined the work as “Lease Operators,” and a subsequent work order requested “A Operators” to perform tasks such as compliance testing and equipment checks on the platforms. The contract required Fieldwood to provide marine transportation for workers and equipment, which it did by hiring Offshore Oil Services, Inc. (OOSI) to transport IOC employees, including Tyrone Felix, to the platforms. Felix was injured while disembarking from OOSI’s vessel, the M/V Anna M, and subsequently made a claim against OOSI.OOSI filed a complaint for exoneration or limitation of liability in the United States District Court for the Eastern District of Louisiana. OOSI also sought indemnification from IOC under the MSC’s indemnity provision. IOC moved for summary judgment, arguing that Louisiana law, specifically the Louisiana Oilfield Anti-Indemnity Act (LOAIA), rendered the indemnity provision unenforceable. The district court agreed, finding that the MSC was not a maritime contract because vessels were not expected to play a substantial role in the contract’s performance, and thus Louisiana law applied. The court granted summary judgment for IOC on indemnity and insurance coverage, and later on defense costs after OOSI settled with Felix.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment de novo. The Fifth Circuit held that the MSC was not a maritime contract because neither its terms nor the parties’ expectations contemplated that vessels would play a substantial role in the contract’s completion. As a result, Louisiana law applied, and the LOAIA barred enforcement of the indemnity provision. The Fifth Circuit affirmed the district court’s summary judgment in favor of IOC. View "Offshore Oil Services, Inc. v. Island Operating Co." on Justia Law

The plaintiff, a former machine operator with a high school education, stopped working after a workplace injury and subsequently experienced a range of medical issues, including spinal stenosis, degenerative joint disease, carpal tunnel syndrome, arthritis, depression, and anxiety. In November 2018, she applied for disability insurance benefits, claiming her disability began in March of that year. Her application was denied at multiple stages within the Social Security Administration (SSA), including after a hearing before an administrative law judge (ALJ). The SSA Appeals Council denied her request for review, prompting her to seek judicial review.The United States District Court for the Northern District of Mississippi reversed and remanded the ALJ’s decision, instructing the ALJ to specifically evaluate certain medical opinions, including that of Dr. William Booker, in accordance with relevant regulations. On remand, the ALJ held another hearing, considered extensive medical evidence and testimony, and again found that while the plaintiff had several severe impairments and could not perform her past work, she retained the residual functional capacity to perform light work with certain restrictions. The ALJ concluded that jobs existed in significant numbers in the national economy that she could perform, and thus she was not disabled. The Appeals Council adopted this as the final decision of the Commissioner. The district court, with the consent of both parties, affirmed the Commissioner’s decision, and the plaintiff appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed whether the Commissioner’s decision was supported by substantial evidence and whether proper legal standards were applied. The court held that the ALJ’s decision was supported by substantial evidence and that any alleged errors did not prejudice the plaintiff’s substantial rights. The court affirmed the judgment of the district court. View "Madkins v. Bisignano" on Justia Law

Texas enacted Senate Bill 1, which included several provisions regulating how individuals may assist voters, particularly those who are blind, disabled, or illiterate. The challenged provisions required assistors to disclose personal information, amended the oath assistors must take, and prohibited compensated assistance or paid ballot harvesting. Various organizations with members who require or provide voting assistance argued that these provisions were preempted by Section 208 of the Voting Rights Act, which allows eligible voters to receive assistance from a person of their choice, with certain exceptions.The United States District Court for the Western District of Texas found that at least one plaintiff organization had standing to challenge each provision. The court held that Section 208 preempted all the challenged provisions, reasoning that the federal law did not permit states to impose additional limitations or exceptions beyond those stated in Section 208. As a result, the district court permanently enjoined state officials and certain district attorneys from enforcing the relevant sections of Senate Bill 1.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision. The Fifth Circuit concluded that none of the plaintiff organizations had standing to challenge the disclosure and oath provisions, as their fears of prosecution were speculative and did not constitute an actual or imminent injury. However, the court agreed that two organizations had standing to challenge the compensation provisions, as there was a credible threat of prosecution for their ongoing activities.Addressing the merits, the Fifth Circuit held that Section 208 of the Voting Rights Act does not preempt Texas’s compensation-related restrictions. The court found no clear and manifest congressional intent to preempt such state regulations and rejected the district court’s broader reading of Section 208. The Fifth Circuit reversed the district court’s judgment, vacated the permanent injunction, and remanded the case for further proceedings. View "La Union del Pueblo Entero v. Abbott" on Justia Law

Five individuals were charged in federal court for their roles in a large-scale drug trafficking operation. The scheme involved purchasing marijuana from states where it was legal, such as California and Oregon, and distributing it to twenty-one other states. The operation used drivers to transport marijuana and related products, with cash proceeds handled outside of financial institutions to avoid detection. Law enforcement investigations included surveillance, traffic stops, and searches of residences, warehouses, and storage units, resulting in the seizure of large quantities of marijuana, THC products, cash, and firearms. The lead investigator analyzed cell phone data to estimate the scope of the conspiracy, concluding it involved over 23,000 kilograms of marijuana.The United States District Court for the Eastern District of Texas indicted the five appellants and ten co-defendants on multiple counts, including conspiracy to possess with intent to distribute marijuana, conspiracy to commit money laundering, and other individualized charges. Eight co-defendants pleaded guilty, while the five appellants went to trial. After an eight-day trial, the jury convicted all five of conspiracy to possess with intent to distribute 1,000 kg or more of marijuana and conspiracy to commit money laundering. Roberts was also convicted of continuing criminal enterprise and possession of a firearm in furtherance of a drug trafficking crime. Sentences ranged from 48 to 240 months’ imprisonment, with some counts dismissed or sentences ordered to run concurrently.The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court affirmed the convictions for conspiracy to possess with intent to distribute marijuana and promotional money laundering, but vacated the sentences for certain defendants due to errors in the admission of a summary chart used to estimate drug quantities and clerical errors in the judgments and presentence reports. The court remanded for resentencing under the default penalty provision and correction of clerical errors, while affirming other aspects of the convictions and venue determinations. View "United States v. McGuire" on Justia Law