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

Jose Paz Medina-Cantu was charged with possession of a firearm and ammunition as an illegal alien, violating 18 U.S.C. §§ 922(g)(5)(A) and 924(a)(2), and illegal reentry into the United States, violating 8 U.S.C. § 1326(a) and (b). He moved to dismiss the firearm possession charge, arguing that the statute was unconstitutional under the Second Amendment, citing the Supreme Court’s decision in New York State Rifle & Pistol Ass’n v. Bruen. The district court denied his motion, referencing the Fifth Circuit’s decision in United States v. Portillo-Munoz, which held that the Second Amendment does not extend to illegal aliens.The United States District Court for the Southern District of Texas denied Medina-Cantu’s motion to dismiss, holding that Bruen did not abrogate the precedent set by Portillo-Munoz. Medina-Cantu then pleaded guilty to both counts without a plea agreement but preserved his constitutional argument for appeal. He was sentenced to fifteen months of imprisonment followed by two years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. Medina-Cantu argued that the Supreme Court’s decisions in Bruen and United States v. Rahimi abrogated Portillo-Munoz. However, the Fifth Circuit held that neither Bruen nor Rahimi unequivocally overruled Portillo-Munoz. The court emphasized that under its rule of orderliness, it could not overturn another panel’s decision unless there was an unequivocal change in the law by the Supreme Court or an en banc decision. Consequently, the Fifth Circuit affirmed the district court’s judgment, upholding the constitutionality of 18 U.S.C. § 922(g)(5) under the Second Amendment. View "USA v. Medina-Cantu" on Justia Law

Curtis Terrell, after consuming a significant amount of alcohol, pain pills, and methamphetamine, began running erratically in a residential neighborhood. His wife, Angela Terrell, called 911, requesting an ambulance. Officer Jason Allgrunn arrived and arrested Mr. Terrell. When Mrs. Terrell began filming the incident, she was also arrested. The Terrells filed multiple federal and state claims against Allgrunn and other officers involved.The United States District Court for the Western District of Louisiana denied summary judgment to the defendants on all claims, rejecting their qualified immunity defense. The defendants appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of summary judgment for the defendants on the Terrells' false arrest claims, finding that Officer Allgrunn had probable cause to arrest both Mr. and Mrs. Terrell. The court also reversed the denial of summary judgment on Mrs. Terrell's excessive force claim, concluding that there was no clearly established law prohibiting the officer's conduct. However, the court dismissed the appeal regarding Mr. Terrell's excessive force claim for lack of jurisdiction, as there were genuine disputes of material fact about what occurred when Mr. Terrell was out of the video frame.Additionally, the court reversed the denial of summary judgment on the Terrells' malicious prosecution and First Amendment retaliation claims, citing the presence of probable cause. The court also reversed the denial of summary judgment for Officers Henderson and Banta on the failure-to-intervene claims, as there were no violations of clearly established constitutional law.Finally, the court vacated the district court's denial of summary judgment on the Louisiana state law claims and remanded for reconsideration in light of the appellate court's opinion. View "Terrell v. Allgrunn" on Justia Law

The case involves a long-standing litigation concerning the Orleans Parish Sheriff’s Office and the conditions at Orleans Parish Prison. Plaintiffs, including detainees and the United States, argued that the jail provided constitutionally inadequate housing and medical care. In 2013, a district court approved a consent decree to address these issues, which included a plan to construct a mental health annex, known as Phase III. Despite years of delays, the district court ordered the construction to proceed. No party appealed these orders at the time.The United States District Court for the Eastern District of Louisiana oversaw the case initially. In 2016, the parties entered a stipulated order to develop a plan for appropriate housing for prisoners with mental health issues. The Compliance Director later proposed the construction of Phase III, which was agreed upon by the former Sheriff and the City. However, the City later sought to explore alternatives, leading to further court orders in 2019 to proceed with Phase III. The City’s subsequent motion to halt the project was denied, and this decision was affirmed by the United States Court of Appeals for the Fifth Circuit in Anderson v. City of New Orleans.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The new Sheriff, Susan Hutson, moved to terminate all orders concerning Phase III, arguing that the Prison Litigation Reform Act (PLRA) prohibits the construction of a new jail facility. The district court denied this motion, and the Fifth Circuit dismissed the appeal for lack of jurisdiction. The court held that it could review the denial of the motion but not the underlying orders, as the Sheriff’s motion was not a proper procedural mechanism under the PLRA to challenge the 2019 Orders and Stipulated Order. The appeal was dismissed, and the construction of Phase III continues. View "Anderson v. Hutson" on Justia Law

Susan Hardy, a resident of Louisiana, flew from Newark, New Jersey, to Oslo, Norway, on Scandinavian Airlines System (SAS). Upon disembarking in Oslo, she fell and fractured her leg. Hardy sued SAS in the Eastern District of Louisiana, claiming that Article 33 of the Montreal Convention provided both subject matter and personal jurisdiction over SAS. The district court dismissed her case, ruling that the Montreal Convention only granted subject matter jurisdiction and not personal jurisdiction. Additionally, the court found that SAS’s waiver of service did not establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2).The United States District Court for the Eastern District of Louisiana dismissed Hardy’s complaint without prejudice. The court concluded that Article 33 of the Montreal Convention did not create personal jurisdiction over SAS. It also rejected Hardy’s argument that SAS’s waiver of service under Federal Rule of Civil Procedure 4(k)(2) established personal jurisdiction, reasoning that SAS did not have sufficient contacts with Louisiana to warrant such jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Article 33 of the Montreal Convention does not independently create personal jurisdiction over a defendant airline, as it only prescribes venue. However, the court found that the district court erred in its analysis under Rule 4(k)(2). The correct analysis should have considered SAS’s contacts with the United States as a whole, not just Louisiana. The Fifth Circuit concluded that SAS had sufficient minimum contacts with the United States to establish personal jurisdiction under Rule 4(k)(2). Consequently, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "Hardy v. Scandinavian Airline System" on Justia Law

Tesla, Inc. and its affiliates challenged a Louisiana law that prohibits automobile manufacturers from selling directly to consumers and performing warranty services for cars they do not own. Tesla alleged that the law violated federal antitrust law, due process rights, and equal protection rights. The defendants included the Louisiana Motor Vehicle Commission, its commissioners, the Louisiana Automobile Dealers Association (LADA), and various dealerships.The United States District Court for the Eastern District of Louisiana dismissed Tesla's claims. The court found that the private defendants were immune from antitrust liability, Tesla had not plausibly pleaded a Sherman Act violation against the governmental defendants, there was insufficient probability of actual bias to support the due process claim, and the regulations passed rational-basis review for the equal protection claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the dismissal of Tesla's due process claim, finding that Tesla had plausibly alleged that the Commission's composition and actions created a possible bias against Tesla, violating due process. The court vacated and remanded the dismissal of the antitrust claim, noting that the due process ruling fundamentally altered the grounds for Tesla's alleged antitrust injury. The court affirmed the dismissal of the equal protection claim, holding that the regulations had a rational basis in preventing vertical integration and controlling the automobile retail market.In summary, the Fifth Circuit reversed the due process claim dismissal, vacated and remanded the antitrust claim dismissal, and affirmed the equal protection claim dismissal. The case was remanded for further proceedings consistent with the court's opinion. View "Tesla v. Louisiana Automobile Dealers" on Justia Law

Fernando Yates, a math teacher in his late sixties, alleged that Spring Independent School District (Spring ISD) discriminated and retaliated against him based on age, race, national origin, color, and disability. Yates was placed on multiple support plans due to performance concerns, reassigned from his eighth-grade math teaching position to a "push-in" role, and later to a seventh-grade math position before being replaced by a younger teacher. He was also placed on administrative leave following complaints from students and parents. Yates filed a Charge of Discrimination with the EEOC and later a lawsuit against Spring ISD.The United States District Court for the Southern District of Texas granted summary judgment in favor of Spring ISD. The court concluded that the actions taken against Yates did not constitute adverse employment actions under the pre-Hamilton standard, which required an "ultimate employment decision." The court also found that Yates failed to establish a prima facie case of age discrimination and that Spring ISD provided legitimate, nondiscriminatory reasons for its actions, which Yates could not prove were pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court acknowledged that the district court had applied an outdated standard but still found that Spring ISD had provided legitimate, nondiscriminatory reasons for its actions. The court held that Yates failed to show that these reasons were pretextual. Consequently, the summary judgment in favor of Spring ISD was affirmed. View "Yates v. Spring Independent School District" on Justia Law

Commercial fishers challenged the constitutionality of the Gulf of Mexico Fishery Management Council's actions, specifically targeting the approval and implementation of Amendment 54, which significantly reduced the greater amberjack catch limit. The plaintiffs argued that the Council members were improperly appointed under the Appointments Clause of the U.S. Constitution and were unconstitutionally insulated from removal. They sought a declaratory judgment and an injunction to set aside the Final Rule implementing the catch limit and to prevent further development of annual catch limits for the greater amberjack fishery.The United States District Court for the Southern District of Mississippi consolidated the cases and granted summary judgment to the government. The court found that six of the Council’s seventeen members were improperly appointed as inferior officers. However, it concluded that the plaintiffs were not entitled to relief because the constitutional violation was not the proximate cause of their injuries. The decision to implement Amendment 54 was made by the NMFS Assistant Administrator, not the Council. Additionally, the court noted that the remaining eleven Council members were properly appointed and constituted a quorum.The United States Court of Appeals for the Fifth Circuit reviewed the case and remanded it to the district court. The appellate court instructed the lower court to determine whether it had jurisdiction to consider the plaintiffs' request to declare Amendment 54 void and to enjoin the Council from developing further catch limits. The district court was also directed to address whether the NMFS Assistant Administrator’s review and approval of the Final Rule functioned as a ratification of the Council’s actions. The appellate court emphasized the need for a thorough district court analysis of the ratification issue before addressing the validity of the Council members' appointments and the plaintiffs' entitlement to relief. View "Arnesen v. Raimondo" on Justia Law

The case involves the Restaurant Law Center and the Texas Restaurant Association challenging a final rule by the Department of Labor (DOL) that restricts when employers can claim a "tip credit" for "tipped employees" under the Fair Labor Standards Act (FLSA). The tip credit allows employers to pay tipped employees a lower hourly wage, assuming tips will make up the difference to meet the minimum wage. The DOL's final rule imposes limits on the amount of non-tip-producing work a tipped employee can perform while still allowing the employer to claim the tip credit.The United States District Court for the Western District of Texas initially denied the plaintiffs' motion for a preliminary injunction, stating they would not suffer irreparable harm. The Fifth Circuit Court of Appeals reversed this decision, finding that the plaintiffs had shown irreparable harm and remanded the case for further consideration. On remand, the district court evaluated the merits and granted summary judgment in favor of the DOL, holding that the final rule was a permissible interpretation of the FLSA under Chevron deference and was neither arbitrary nor capricious.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the final rule was contrary to the clear statutory text of the FLSA and was arbitrary and capricious. The court held that the FLSA's definition of a "tipped employee" does not support the DOL's restrictions on non-tip-producing work. The court concluded that the final rule improperly focused on the pursuit of tips rather than the duties of the occupation itself. Consequently, the Fifth Circuit reversed the district court's summary judgment in favor of the DOL, rendered summary judgment for the plaintiffs, and vacated the final rule. View "Restaurant Law Center v. Department of Labor" on Justia Law

In 2019, Ancor Holdings, L.P. (Ancor) and Landon Capital Partners, L.L.C. (Landon) entered into letters of intent to invest in and acquire a majority interest in ICON EV, L.L.C. (ICON). The deal fell through, and Landon and ICON entered into their own agreement. Ancor sued Landon and ICON for breach of contract and tortious interference, respectively. The trial court dismissed Ancor’s tortious interference claim against ICON as a matter of law and denied Ancor’s declaratory judgment claim. The jury found for Ancor on the breach of contract claim against Landon, awarding $2,112,542 in damages.The United States District Court for the Northern District of Texas initially handled the case. The trial court dismissed Ancor’s tortious interference claim against ICON and denied Ancor’s declaratory judgment claim. The jury found Landon breached the contract and awarded Ancor damages. Ancor appealed the dismissal of its claims, and Landon cross-appealed the jury’s verdict.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the trial court’s dismissal of Ancor’s declaratory judgment and tortious interference claims, remanding them for a jury trial. The appellate court affirmed the jury’s finding that Landon breached the contract but reversed the trial court’s judgment on the reimbursement amount, instructing it to determine 80% of all third-party costs incurred. The court held that Ancor was entitled to a jury trial on its declaratory judgment claim and that sufficient evidence supported the tortious interference claim against ICON. The court also found that the trial court did not err in submitting the breach of contract claim to the jury, nor did the jury err in its findings. View "Ancor Holdings, L.P. v. Landon Capital Partners, L.L.C." on Justia Law

Bobby Stevenson, a prisoner at the Louisiana State Penitentiary, claims he was forced to labor in the prison’s agricultural fields despite severe ankle pain caused by two broken surgical screws. He alleges that two prison physicians, Dr. Randy Lavespere and Dr. Paul M. Tocé, refused to fix the screws or relieve him from field labor. Stevenson asserts that the broken screws caused him tremendous pain and secondary injuries, and that the physicians ignored his complaints and medical recommendations for surgery.The United States District Court for the Middle District of Louisiana reviewed the case. The magistrate judge allowed Stevenson to file an amended complaint and recommended denying the defendants' motion to dismiss, which argued for qualified immunity. The district court accepted this recommendation and denied the motion, leading to the current appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Stevenson sufficiently alleged that the defendants violated his Eighth Amendment rights by ignoring his severe medical needs and forcing him to work despite his condition. The court also determined that the defendants had fair warning from existing case law that their actions were unconstitutional. Consequently, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss, rejecting the defendants' claim of qualified immunity. View "Stevenson v. Toce" on Justia Law