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

John Gilchrist and Byron Brockman sued their former employer, Schlumberger Technology Corp., for failing to pay them overtime in violation of the Fair Labor Standards Act (FLSA). They worked as Measurements While Drilling Field Specialists (MWDs), providing essential data to Schlumberger's clients for drilling operations. Their duties included monitoring drilling data, ensuring data quality, and advising clients on drilling operations. Both earned over $200,000 annually but were not paid overtime.The United States District Court for the Western District of Texas held a bench trial and found that Schlumberger failed to prove that Gilchrist and Brockman were exempt from the FLSA's overtime requirements under the Highly Compensated Employee (HCE) exemption. The court determined that their duties did not qualify as administrative or executive tasks that would exempt them from overtime pay. Schlumberger appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Gilchrist and Brockman qualified as highly compensated employees exempt from the FLSA's overtime pay requirement because they performed administrative duties, specifically quality control and advisory roles, which are directly related to the management or general business operations of Schlumberger's clients. The court noted that the MWDs' tasks were performed customarily and regularly, meeting the criteria for the HCE exemption. Consequently, the appellate court remanded the case with instructions to dismiss the claims for overtime pay. View "Gilchrist v. Schlumberger" on Justia Law

Joseph Terrell Goody, a documented gang member with a lengthy criminal history, was convicted of possession of a firearm by a felon. His criminal record includes convictions for cocaine possession, robbery, assault, deadly conduct, evading arrest, and burglary. On September 26, 2020, Goody was pulled over for traffic violations, and officers found cocaine, methamphetamine, and a suspicious guitar case in his car. The case contained a loaded rifle. Goody was arrested and later pleaded guilty to violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2).The United States District Court for the Southern District of Texas sentenced Goody to 57 months of imprisonment and two years of supervised release, with a special condition prohibiting him from associating with gang members. Goody appealed his conviction and the supervised-release condition.The United States Court of Appeals for the Fifth Circuit reviewed the case. Goody raised three arguments on appeal: the facial unconstitutionality of the felon-in-possession ban under the Second Amendment, a violation of the equal protection principle under the Fifth Amendment, and the vagueness of the supervised-release condition. The court rejected all three arguments. It upheld the constitutionality of the felon-in-possession ban, found no merit in the equal protection claim, and determined that the supervised-release condition was not plainly erroneous. The court noted that similar conditions have been routinely imposed and upheld by other courts. Consequently, the Fifth Circuit affirmed the district court's judgment. View "United States v. Goody" on Justia Law

A Texas statute, Senate Bill 315, prohibits individuals under 21 from working at sexually oriented businesses (SOBs) to prevent sex trafficking and sexual exploitation. Plaintiffs, including the Texas Entertainment Association and several adult cabarets and bookstores, challenged the constitutionality of S.B. 315 under the First Amendment, suing the Texas Attorney General and the Executive Director of the Texas Workforce Commission.The United States District Court for the Western District of Texas held a bench trial and upheld the statute as constitutional. The court found that Texas enacted S.B. 315 with the reasonable belief that it would curb sex trafficking and that the law was sufficiently tailored to that end. The court applied intermediate scrutiny, concluding that the statute furthered the state's interest in reducing sex trafficking and did not restrict substantially more speech than necessary.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that intermediate scrutiny was appropriate. The court found that S.B. 315 was designed to serve a substantial governmental interest by providing evidence linking SOBs to sex trafficking and sex crimes. The court also determined that the statute allowed for reasonable alternative avenues of communication, as it did not significantly restrict the expressive conduct of SOBs or their employees. The court concluded that S.B. 315 was not overbroad, as the plaintiffs failed to demonstrate that the statute prohibited or chilled a substantial amount of protected speech. Thus, the Fifth Circuit held that S.B. 315 is constitutional under the First Amendment. View "Ass’n of Club Executives v. Paxton" on Justia Law

A nonprofit organization, Students for Fair Admissions (SFFA), challenged the University of Texas at Austin (UT) for its admissions policies, alleging they violated the Equal Protection Clause and Title VI by considering race as a factor. After the Supreme Court's decision in Students for Fair Admissions, Inc., v. President & Fellows of Harvard College, UT revised its admissions policy to exclude race as a factor but allowed admissions officers access to applicants' racial data. SFFA claimed this access still constituted a violation and sought declaratory and injunctive relief.The United States District Court for the Western District of Texas dismissed all claims as moot, reasoning that UT's policy changes addressed the issues raised by SFFA. The district court concluded that the claims related to the old policy were moot and that the new policy did not violate the law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court agreed that claims related to UT's pre-Harvard policy were moot because the policy had been repealed and could not reasonably be expected to recur. However, the court found that claims related to UT's post-Harvard policy were not moot. The court noted that admissions officers' access to racial data could still potentially allow for racial discrimination, thus maintaining a live controversy.The Fifth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The court held that SFFA's claims regarding the revised admissions policy remained live and required further examination to determine if the policy was a subterfuge for continued race discrimination. View "Students for Fair Admissions v. University of Texas Austin" on Justia Law

In 2010, the British Petroleum Deepwater Horizon oil spill released crude oil into the Gulf of Mexico. Matthew Williams, the plaintiff, performed oil spill clean-up work in the Gulf that summer. On September 24, 2020, Williams was diagnosed with chronic pansinusitis, an inflammatory condition of the nasal passages. Williams filed a lawsuit against BP Exploration & Production Inc. and BP America Production Co., alleging that his condition was caused by exposure to oil, dispersants, and other chemicals during the cleanup work. Williams presented two expert witnesses, Dr. Michael Freeman and Dr. James Clark, to establish causation.The United States District Court for the Southern District of Mississippi reviewed the case. BP filed motions to exclude the expert reports under Federal Rule of Evidence 702 and Daubert, and subsequently filed a motion for summary judgment, arguing that Williams lacked admissible expert testimony to establish causation. The district court granted BP’s motions to exclude the expert testimonies and the motion for summary judgment, leading Williams to appeal the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court upheld the district court’s exclusion of Dr. Freeman’s testimony, finding it unreliable as it did not properly apply the differential etiology approach. Similarly, the court found Dr. Clark’s testimony unreliable due to errors in his report, including references to another case and incorrect assumptions about benzene concentrations. Without admissible expert testimony, Williams could not establish specific causation, a necessary element in toxic tort cases. Consequently, the Fifth Circuit affirmed the district court’s grant of summary judgment in favor of BP. View "Williams v. BP Expl & Prod" on Justia Law

William Navarre purchased a house that had been damaged by two hurricanes in 2020. The previous owners, Bal and Rita Sareen, had received insurance payments from AIG Property Casualty Company but had not assigned their post-loss insurance rights to Navarre at the time of the sale. Navarre filed a lawsuit against AIG, claiming he had been assigned these rights as of the purchase date. However, the formal assignment document was not executed until January 2023, well after the lawsuit was filed and after the prescriptive period for the claims had expired.The United States District Court for the Western District of Louisiana granted summary judgment in favor of AIG, concluding that Navarre lacked standing to file the lawsuit because the assignment of rights had not been executed at the time he filed the suit. The court also noted that the prescriptive period for the claims had expired by the time the assignment was executed.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed that the documents Navarre relied on (Addendum A and the Side Letter) did not constitute a present assignment of rights but rather contemplated a future assignment. Since the formal assignment was not executed until January 2023, Navarre did not have standing to sue when he filed the lawsuit in June 2022. Additionally, the court held that the prescriptive period for the claims had expired by the time the assignment was executed, and thus, Navarre could not retroactively cure the deficiency in his original petition. View "Navarre v. AIG Prop Cslty" on Justia Law

Ronnie Alexander was arrested and detained in Henderson County Jail while awaiting trial. He falsely informed jail officials that he was suicidal to be transferred out of the group holding cell. Consequently, he was moved to the jail's suicide-prevention cell, known as the "violent cell," which lacked basic amenities such as a toilet, running water, or bedding, and had lights on at all hours. Alexander was housed there for five days before being released. He subsequently filed a lawsuit challenging the conditions of his confinement and the adequacy of the jail's mental health services.The United States District Court for the Northern District of Texas granted the defendants' motions to dismiss Alexander's federal and state-law claims. The court found that Alexander failed to state a claim under 42 U.S.C. § 1983 against the Taft defendants, Henderson County, and the correctional officers. The court also declined to exercise supplemental jurisdiction over Alexander's remaining state-law claims and dismissed them without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The court held that the conditions of the violent cell were reasonably related to the legitimate governmental interest of protecting suicidal inmates from self-harm. The court found that the conditions, although harsh, were not punitive and did not violate Alexander's constitutional rights. The court also determined that the mental health care provided to Alexander met the constitutional minimum required, and there was no deliberate indifference by the Taft defendants or the county. Consequently, Alexander's claims were dismissed. View "Alexander v. Taft" on Justia Law

An employee at an Apple retail store in New York City, Jordan Vasquez, was involved in union organizing efforts with the Communication Workers of America. During a conversation with his senior manager, Stephanie Gladden, Vasquez claimed that Gladden asked him about his union activities, which he denied being involved in. Gladden, however, testified that Vasquez himself brought up the topic of unions. Additionally, Apple managers removed union flyers from the breakroom table, citing general housekeeping and non-solicitation policies.The National Labor Relations Board (NLRB) found that Apple violated the National Labor Relations Act (NLRA) by coercively interrogating Vasquez and by removing union literature from the breakroom. An Administrative Law Judge (ALJ) credited Vasquez's account over Gladden's and concluded that Apple had engaged in unfair labor practices. The NLRB affirmed the ALJ's findings and ordered Apple to cease and desist from these violations and to post a remedial notice.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that substantial evidence did not support the NLRB's conclusions. The court determined that Gladden's conversation with Vasquez did not constitute coercive interrogation under the totality of the circumstances, noting the lack of employer hostility or threats of reprisal. The court also found that Apple consistently enforced its housekeeping and non-solicitation policies, removing various non-union materials from the breakroom, and thus did not discriminatorily target union literature.The Fifth Circuit granted Apple's petition for review and reversed the NLRB's findings, concluding that Apple did not violate the NLRA in either instance. View "Apple v. NLRB" on Justia Law

Detective Genaro Hernandez, a Dallas Police Department detective, was involved in a shooting investigation outside The Green Elephant bar in August 2019. Hernandez, who also worked for the Stainback Organization, allegedly pursued false charges against the bar's owner, Shannon McKinnon, and a security guard, Guadalupe Frias, to benefit his private employer. Despite the Special Investigation Unit finding no criminal offense by the plaintiffs, Hernandez bypassed standard procedures and directly sought prosecution from the Dallas County District Attorney’s Office, leading to the plaintiffs' indictment for tampering with evidence. The charges were later dropped when Hernandez's conflict of interest was revealed during Frias's trial.The plaintiffs filed a lawsuit against Hernandez, alleging federal claims under 42 U.S.C. § 1983 for false arrest and malicious prosecution, and state-law claims for malicious prosecution, false imprisonment, and civil conspiracy. The United States District Court for the Northern District of Texas dismissed the federal malicious-prosecution claim but allowed the federal false-arrest claim and the state-law claims to proceed. Hernandez appealed, arguing he was entitled to governmental immunity under the Texas Tort Claims Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Hernandez's actions, despite being motivated by personal interests, fell within the scope of his employment as a detective. The court held that Texas law provides broad immunity to state actors for actions within their employment scope, regardless of intent. Consequently, the court reversed the district court's decision denying dismissal of the state-law claims and remanded the case for further proceedings on the remaining federal claim. View "Frias v. Hernandez" on Justia Law

A real estate developer, HK Baugh Ranch, LLC, petitioned the Texas Public Utility Commission (PUC) to release its undeveloped land, River Bend Ranch, from the certificate of convenience and necessity (CCN) issued to Crystal Clear Special Utility District (Crystal Clear). Crystal Clear, a federally indebted utility district, sued the PUC’s Chair and Commissioners in federal court, alleging that Texas Water Code § 13.2541, which allows for decertification, was preempted by 7 U.S.C. § 1926(b). This federal statute protects certain federally indebted utilities from curtailment of their service areas while their loans are outstanding.The United States District Court for the Western District of Texas issued a preliminary injunction preventing the PUC from decertifying River Bend Ranch. The district court applied the “physical ability” test from Green Valley Special Utility District v. City of Schertz, determining that Crystal Clear likely made its service available to HK Baugh and was thus entitled to the protections of § 1926(b). The court concluded that § 1926(b) likely expressly preempts Texas Water Code § 13.2541, resolving the remaining preliminary injunction factors in favor of Crystal Clear.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not err in concluding that Crystal Clear would likely satisfy the “physical ability” test. However, the appellate court found that the district court erred in holding that § 1926(b) expressly preempts Texas Water Code § 13.2541. The appellate court remanded the case to the district court to determine whether § 1926(b) otherwise preempts Texas Water Code § 13.2541 and to address all preliminary injunction factors as necessary. The preliminary injunction remains in place pending further proceedings. View "Crystal Clear v. HK Baugh Ranch" on Justia Law