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

Several individuals who worked as waitstaff at a club operated by Benelux Corporation brought a lawsuit in 2024, alleging violations of the Fair Labor Standards Act. In 2020, Benelux had distributed an arbitration agreement to its employees. The agreement included two signature boxes—one for the employee and one for Benelux’s representative—and stated that by signing, both parties represented that they had read and understood the agreement and agreed to be bound by its terms. One employee, Cadena, signed both signature boxes, but Benelux’s general manager did not sign the agreement due to an oversight.After being sued, Benelux moved to compel arbitration based on the unsigned agreement. Cadena argued that the agreement was not enforceable because Benelux had not signed it, stating she did not intend to be bound unless Benelux also signed. The United States District Court for the Western District of Texas adopted the Magistrate Judge’s recommendation and denied Benelux’s motion to compel, finding that the agreement required signatures from both parties to be enforceable, and Benelux had not signed.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. Applying Texas contract law, the Fifth Circuit held that the language of the arbitration agreement clearly required signatures from both the employee and Benelux’s representative for the agreement to be enforceable. Because Benelux did not sign, there was no valid arbitration agreement between Benelux and Cadena. The court affirmed the district court’s judgment denying Benelux’s motion to compel arbitration. View "Mertens v. Benelux Corporation" on Justia Law

James Devins, a pro se plaintiff, sought to sponsor a Nepali citizen, Rita Raut, for a U.S. student visa as part of his religious practice, which he described as involving “parental and patriotic guidance” and “spiritual and intellectual mentorship.” Raut’s visa applications were denied three times between 2021 and 2023. After the last denial, Devins filed three separate lawsuits relating to the visa refusal, each time alleging a violation of his rights under the Religious Freedom Restoration Act (RFRA).The United States District Court for the Western District of Texas dismissed Devins’s first suit against the Director of United States Citizenship and Immigration Services for lack of standing, without prejudice. In his second suit against the Assistant Secretary of State for Consular Affairs, the district court also dismissed the case without prejudice, citing a lack of subject matter jurisdiction based on standing and the doctrine of consular nonreviewability. In his third and current action, Devins again sued the Assistant Secretary, raising substantially the same claim based on the same events and added no new factual allegations.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision to dismiss the third action with prejudice based on the doctrine of res judicata. The Fifth Circuit held that all requirements for res judicata were met: the parties were identical or in privity, the prior judgments were final and on the merits as to jurisdiction, and the same claim was involved in all actions. The court concluded that further litigation was precluded, as Devins had not alleged any new injury or change in circumstances that would alter the prior jurisdictional rulings. The Fifth Circuit affirmed the district court’s dismissal with prejudice. View "Devins v. Armstrong" on Justia Law

A passenger, after being injured in a hit-and-run rear-end collision while riding in a vehicle arranged through a rideshare application, sought damages for bodily injuries. The passenger alleged that the rideshare company, its subsidiary, and its insurer either provided or were required by law to provide uninsured motorist (UM) coverage, and that their rejection of such coverage violated Louisiana law.The action began in Louisiana state court, initially naming only the insurer as a defendant. The passenger later amended the complaint to add the rideshare company and its subsidiary, arguing that they were not permitted to reject UM coverage. With all defendants’ consent, the insurer removed the case to the United States District Court for the Eastern District of Louisiana, citing diversity jurisdiction. Multiple motions followed, including motions to dismiss by the rideshare entities and a motion for summary judgment by the insurer. The district court found that Louisiana statutes allow transportation network companies to reject UM coverage and that the defendants had properly done so. Accordingly, the district court dismissed all claims with prejudice and denied the passenger’s request to certify a question to the Louisiana Supreme Court.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the statutory interpretation de novo. The court concluded that Louisiana Revised Statute § 45:201.6 incorporates, by general reference, the provisions of § 22:1295, including the right to reject UM coverage. The court found support for this interpretation in state appellate decisions and statutory context. The Fifth Circuit affirmed the district court’s judgment and denied the motion to certify the question to the Louisiana Supreme Court. The holding is that transportation network companies in Louisiana may reject uninsured motorist coverage if they follow the procedures in § 22:1295. View "Guerrera v. United Financial Casualty Co." on Justia Law

The case centers on Kristal Glover-Wing, who founded and operated Angel Care Hospice (ACH) in Louisiana, a Medicare-certified hospice provider. ACH’s business model involved recruiting local physicians as medical directors who referred patients and certified them as terminally ill, even when evidence showed many patients maintained active lifestyles inconsistent with terminal illness. Glover-Wing instructed staff to emphasize patients’ worst conditions in records and resisted discharging patients who no longer qualified, sometimes directing staff to falsify records or reenroll patients after hospitalizations. An investigation revealed that, for at least twenty-four patients, hospice services were provided and Medicare reimbursed ACH over $1.5 million, despite the patients not meeting eligibility criteria.Following a whistleblower complaint and investigation, a federal grand jury in the United States District Court for the Western District of Louisiana indicted Glover-Wing and two physicians for conspiracy to commit healthcare fraud and three counts of healthcare fraud. During trial, the jury asked if the conspiracy charge could include ACH employees as coconspirators, leading to a dispute over jury instructions. Glover-Wing requested judicial estoppel to prevent the government from expanding the conspiracy beyond named defendants, arguing she relied on prior government representations. The district court denied her requests, and the jury convicted Glover-Wing on all counts while acquitting the physicians. Post-trial, the district court denied Glover-Wing’s motions for acquittal and a new trial.The United States Court of Appeals for the Fifth Circuit reviewed Glover-Wing’s sufficiency-of-evidence and judicial estoppel claims. The court held that sufficient evidence supported all convictions, as a rational jury could find Glover-Wing knowingly participated in fraud and conspiracy. It further held that judicial estoppel did not apply because the government’s positions were not plainly inconsistent, nor accepted by the court, and Glover-Wing failed to show unfair detriment. The Fifth Circuit affirmed the district court’s judgment. View "United States v. Glover-Wing" on Justia Law

During a traffic stop in Hidalgo County, Texas, a sheriff’s deputy pulled over Gerardo Villarreal for driving with a partially obscured license plate. The deputy discovered Villarreal did not have a driver’s license or insurance. After a canine sniff alerted to an item in the vehicle, officers searched the car, finding a handgun and a small amount of cocaine. Villarreal was later indicted for being a felon in possession of a firearm under federal law. He moved to suppress the handgun as evidence, arguing the search violated his Fourth Amendment rights.The United States District Court for the Southern District of Texas held a hearing on the motion to suppress. The court heard testimony from the arresting deputy, who explained that department policy generally required impounding vehicles when the driver lacked a license or insurance, with certain exceptions. The deputy testified he would have impounded Villarreal’s vehicle and performed an inventory search, which would have revealed the handgun. Villarreal attempted to impeach this testimony, referencing another incident where the deputy did not impound a vehicle under similar circumstances, but the deputy explained possible exceptions. The district court found the deputy credible and denied the motion to suppress, applying the inevitable-discovery doctrine.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the inevitable-discovery doctrine applied because the government showed by a preponderance of the evidence that an inventory search, conducted pursuant to standard department policy, would have discovered the handgun. The court found that the impounding and inventory search were imminent before any alleged misconduct, and the department’s policy sufficiently limited officer discretion. The Fifth Circuit affirmed the district court’s judgment, upholding denial of the motion to suppress. View "USA v. Villarreal" on Justia Law

A Texas law, Senate Bill 17, prohibits individuals who are domiciled in certain “designated countries,” including China, from acquiring interests in Texas real estate. The law defines “domicile” as a person’s true, fixed, and permanent home to which the individual intends to return whenever absent. Peng Wang, a Chinese citizen who has lived in Texas for sixteen years on an F-1 student visa, challenged the law’s constitutionality. Wang attends school in Texas, intends to remain in the state after graduation, and does not plan to return to China.The United States District Court for the Southern District of Texas dismissed Wang’s suit for lack of jurisdiction, holding that he lacked standing. The district court found that Wang was not domiciled in China based on his long-term residence and stated intentions to remain in Texas. The court also concluded that Wang faced no substantial risk of future enforcement of the statute against him, citing repeated in-court statements by the Texas Attorney General disavowing any intent to enforce the law against Wang.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. It affirmed the district court’s dismissal, holding that Wang lacked standing for two independent reasons. First, Wang failed to allege he was domiciled in China, so the statute did not arguably proscribe his conduct. Second, he did not demonstrate a credible threat of enforcement of the law, given the Attorney General’s in-court assurances and lack of any enforcement action or procedures targeting Wang. The Fifth Circuit therefore affirmed the dismissal for lack of jurisdiction. View "Wang v. Paxton" on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

Federal and state law enforcement officers executed a search warrant at the home and business of George Peterson, a federally licensed firearms dealer operating out of his residence in Louisiana. The warrant was supported by an affidavit detailing months of investigation by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), including undercover purchases where Peterson failed to report firearm sales as required and sold firearms under circumstances suggesting knowledge of illegal transactions. During the search, agents discovered a homemade, unregistered firearm suppressor in Peterson’s closet safe. The suppressor lacked a serial number and was not registered as required by the National Firearms Act (NFA).A grand jury in the United States District Court for the Eastern District of Louisiana indicted Peterson for possession of an unregistered suppressor in violation of the NFA. Peterson moved to dismiss the indictment, arguing the NFA’s registration scheme violated his Second Amendment rights as applied to him, and also moved to suppress the evidence, claiming the search violated the Fourth Amendment. The district court denied both motions. Peterson entered a conditional guilty plea, reserving the right to appeal those rulings. He was sentenced to twenty-four months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decisions. The court held that, assuming suppressors are protected by the Second Amendment, the NFA’s “shall-issue” licensing and registration regime is presumptively constitutional under New York State Rifle & Pistol Association v. Bruen and related precedent. Peterson failed to show that the NFA’s requirements denied him his rights or were applied abusively. Regarding the motion to suppress, the court found that the good-faith exception to the exclusionary rule applied because the officers reasonably relied on a warrant issued by a magistrate judge, even if probable cause was disputed. Thus, both denials were affirmed. View "United States v. Peterson" on Justia Law

Two brothers sought multimillion-dollar loans from a bank to fund oil and gas investments. Because the bank required collateral, one brother arranged for a third party to create fraudulent documents making it appear that a securities account was worth millions. The brothers paid the third party for these fake statements, and, over several years, borrowed millions from the bank. They used some of the loan proceeds for improper purposes, including personal expenses and paying for the fake account statements. The bank eventually discovered the fraud after questioning the third party, who confessed and cooperated with the government, leading to indictments for conspiracy to commit bank fraud and money laundering.Prior to trial, the case was assigned to a district judge who had previously represented the victim bank in unrelated civil matters. One brother pled guilty to conspiracy to commit bank fraud before trial, while the other, Phillip, went to trial. The district court denied motions to dismiss the indictment, sever the defendants, and for the judge’s recusal. It also admitted certain evidence and denied several of Phillip’s proposed jury instructions. After a jury found Phillip guilty on all counts, he was sentenced to concurrent prison terms and supervised release. He appealed, raising issues related to the judge’s recusal, evidentiary rulings, prosecutorial delay, instructions, and sufficiency of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district judge was not required to recuse himself due to his prior, unrelated representation of the bank. The court found no reversible error in the handling of co-conspirators’ pleas or other evidentiary rulings, found no grounds for dismissal due to prosecutorial delay, and held that the jury instructions were adequate. The court also found the evidence sufficient to support the convictions and rejected the cumulative error argument. The convictions were affirmed. View "USA v. Page" on Justia Law

The case concerns Holly Ann Elkins, who, along with her fiancé Andrew Beard, engaged in stalking and harassing Beard’s ex-girlfriend, Alyssa Burkett. Their actions included installing a GPS tracker on Burkett’s car, making false police reports, and plotting to plant incriminating evidence. These efforts were intended to gain custody of Beard’s child. Ultimately, Beard murdered Burkett, with Elkins providing assistance, such as purchasing materials used in the crime. Elkins was subsequently convicted by a jury of conspiracy to stalk, cyberstalking resulting in death, and using a firearm during a crime of violence.The United States District Court for the Northern District of Texas sentenced Elkins to five years for conspiracy, a life sentence for cyberstalking resulting in death, and a consecutive life sentence for the firearm offense. Elkins appealed to the United States Court of Appeals for the Fifth Circuit, focusing on the firearm conviction and its associated life sentence. She argued that the underlying cyberstalking offense could not serve as a predicate “crime of violence” for the firearm charge under 18 U.S.C. § 924(c).The United States Court of Appeals for the Fifth Circuit held that the relevant cyberstalking statute, specifically 18 U.S.C. § 2261A(2)(B), is not categorically a “crime of violence” because it does not require as an element the use, attempted use, or threatened use of physical force, even if death results. Consequently, the court vacated Elkins’s conviction and life sentence for the firearm charge. The court affirmed her convictions and sentences on the other counts, rejecting challenges related to the Commerce Clause, jury instructions, and alleged judicial bias. View "USA v. Elkins" on Justia Law