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

The case centers on a plaintiff who filed a Fair Labor Standards Act suit for unpaid wages and recordkeeping violations against his former employer. The plaintiff’s attorney, who neither resides nor holds an office near the courthouse, failed to appoint local counsel within the required timeframe due to a calendaring error. Pursuant to the district court’s local rule, a notice was issued warning that failure to comply could result in dismissal. After the deadline passed without compliance, the district court dismissed the case without prejudice, citing failure to prosecute or comply with court rules.Following the dismissal, the plaintiff promptly moved to reopen the case under Federal Rule of Civil Procedure 60(b)(1), arguing that his attorney’s oversight constituted excusable neglect, and appointed local counsel. The district court denied the motion, reasoning that the plaintiff had not shown that dismissal without prejudice amounted to dismissal with prejudice, and cited prior Fifth Circuit cases as support. The plaintiff filed a second motion, distinguishing his case from the cited cases and again seeking relief, but the district court denied this motion as well, applying the same reasoning.The United States Court of Appeals for the Fifth Circuit reviewed the denial of the Rule 60(b) motions for abuse of discretion. The appellate court held that the district court erred by imposing a requirement that the plaintiff show dismissal without prejudice functioned as a dismissal with prejudice before granting relief under Rule 60(b). The Fifth Circuit clarified that neither Campbell v. Wilkinson nor Jones v. Meridian Security Insurance Company established such a standard for Rule 60(b) motions. The appellate court vacated the district court’s denials of the plaintiff’s motions and remanded for further proceedings, instructing the district court to consider the proper factors for excusable neglect under Rule 60(b)(1). View "Deras v. Johnson & Johnson" on Justia Law

In 1995, a woman was murdered in Houston, and Carlos Ayestas was convicted of capital murder and sentenced to death. Years later, Ayestas’s counsel discovered an internal memorandum from the prosecution recommending the death penalty in part because Ayestas was not a U.S. citizen. This memorandum had not been disclosed during Ayestas’s trial. Ayestas then sought to amend his federal habeas petition to add Eighth and Fourteenth Amendment selective-prosecution claims, arguing that the prosecution’s decision was improperly influenced by his non-citizen status.The United States District Court for the Southern District of Texas denied Ayestas’s motion to amend, finding it constituted a “second or successive habeas corpus application” barred by 28 U.S.C. § 2244(b) because the claims could have been discovered earlier with due diligence. Subsequent Supreme Court decisions clarified the law on what constitutes a “second or successive” application, prompting Ayestas to seek relief under Rule 60(b). The district court granted this motion, allowed discovery on Ayestas’s selective-prosecution claims, and ordered the Harris County District Attorney’s Office (HCDA) to produce decades of charging memoranda and the full prosecutorial file.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the discovery order was immediately appealable by the HCDA under the collateral-order doctrine. The Fifth Circuit determined the district court lacked jurisdiction over Ayestas’s selective-prosecution claims because both his 2015 motion to amend and his later Rule 60(b) motion constituted successive habeas applications barred by § 2244(b). The court concluded that Ayestas had not shown the claims were based on a new rule of constitutional law or that the underlying facts could not have been discovered earlier with due diligence. The Fifth Circuit vacated the discovery order and dismissed the selective-prosecution claims. View "Ayestas v. Harris County" on Justia Law

A teacher at a Texas junior high school, who is a practicing Christian, regularly engaged in prayer and Bible study with other teachers before the school day. In September 2023, she invited staff to join her in prayer at the school flagpole prior to a student-led prayer event. The school principal responded by stating that district policy prohibited employees from praying “with or in the presence of students” and clarified that even if students were not directly involved, teachers could not pray where students might see them, even before official school hours. When the teacher and colleagues prayed near the flagpole, the principal stopped them, reiterating the prohibition on visible religious conduct.The teacher filed suit in the United States District Court for the Southern District of Texas, alleging violations of her First Amendment free speech and free exercise rights, as well as Fourteenth Amendment equal protection and due process claims, and state law claims. The district court denied the principal’s motion to dismiss on the grounds of qualified immunity regarding the First Amendment and equal protection claims, but granted dismissal of the due process claim. The court held that the complaint plausibly alleged a categorical, visibility-based restriction on teacher prayer, and that Kennedy v. Bremerton School District had clearly established the unconstitutionality of such conduct.On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The appellate court affirmed the district court’s denial of qualified immunity for the free speech and free exercise claims, holding that a categorical ban on visible private prayer by teachers, merely because students might observe, violated clearly established First Amendment rights. However, the appellate court reversed as to the equal protection claim, finding that the teacher had not alleged facts showing the principal individually treated her differently than similarly situated employees. The disposition was affirmed in part and reversed in part. View "Barber v. Rounds" on Justia Law

The case involves an early-morning stop of Juan Jose Ponce at a border checkpoint in Sarita, Texas, where a Border Patrol agent, Carlos Garcia, questioned him and observed unusual features in his vehicle. Ponce was driving an SUV with a roof rack but was transporting a ladder inside the car, which Garcia found atypical. Ponce appeared nervous and wore a surgical mask despite traveling alone. Upon request, Ponce consented to unlocking and opening the back hatch of his SUV for Garcia to look inside. During this inspection, Garcia noticed a speaker box with loose screws, which—based on his experience—suggested it might conceal contraband or a person. Garcia opened the speaker box and found a woman unlawfully in the United States. Ponce was indicted for transporting an undocumented person.Proceedings began in the United States District Court for the Southern District of Texas, where Ponce moved to suppress the evidence, arguing the search of the speaker box exceeded his consent and lacked probable cause. The district court held a hearing where both Ponce and Garcia testified. The court found Ponce’s consent to be valid, voluntary, and extending to containers within the vehicle. Even if consent did not reach the speaker box, the court determined Garcia obtained probable cause during his inspection. The district court denied the suppression motion, and Ponce entered a conditional guilty plea while preserving his right to appeal.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the lower court’s findings for clear error and legal conclusions de novo. The Fifth Circuit held that, based on the totality of the circumstances, Garcia obtained probable cause to search the speaker box during the consensual inspection. The court affirmed that Garcia’s actions were consistent with the Fourth Amendment, and upheld the denial of Ponce’s motion to suppress. View "USA v. Ponce" on Justia Law

The plaintiff brought employment discrimination and retaliation claims against the defendants, his former employers, alleging violations of federal and state law. After initiating the lawsuit in July 2021, the plaintiff failed over several years to respond to the defendants’ discovery requests, despite multiple court orders and continuances. The plaintiff’s attorney repeatedly missed deadlines, did not answer interrogatories or produce documents, and failed to pay court-ordered attorney’s fees. Even after the court vacated its scheduling order, delayed the trial multiple times, and assessed additional attorney’s fees, the plaintiff’s counsel did not advance the case, leading to three continuances and a case that remained undeveloped.The United States District Court for the Western District of Louisiana responded to the plaintiff’s ongoing lack of participation by granting the defendants’ motion to exclude all evidence when the fourth trial date approached with no discovery completed. The plaintiff’s counsel did not attend the status conference regarding the exclusion motion despite acknowledging notice. With no admissible evidence remaining, the court then granted the defendants’ motion to dismiss the case with prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed both the exclusion of evidence and the dismissal with prejudice for abuse of discretion. The court held that the district court correctly applied the standard four-factor test for exclusion of evidence as a discovery sanction and was not required to apply a heightened standard for litigation-ending sanctions. The court further found that a clear record of delay existed, lesser sanctions had proven futile, and the defendants were prejudiced by the plaintiff’s failures. Accordingly, the Fifth Circuit affirmed the district court’s judgment dismissing the case with prejudice. View "Savage v. LaSalle Management" on Justia Law

An employee of a major defense contractor, serving in a senior internal audit role, claimed to have discovered fraudulent activity involving government contracts for military aircraft. The contractor, which assembles aircraft using parts supplied by numerous subcontractors, is subject to detailed regulatory requirements intended to ensure fair pricing, including the Truth in Negotiations Act (TINA), the Federal Acquisition Regulation (FAR), and the Defense Federal Acquisition Regulation Supplement (DFARS). The plaintiff alleged that the contractor systematically ignored and concealed fraudulent inflation of cost and pricing data by its subcontractors, resulting in overbilling the government.The plaintiff brought a qui tam action under the False Claims Act (FCA), which allows private individuals to sue on behalf of the government. Previously, another relator had filed a separate FCA action against the same contractor, alleging a different fraudulent scheme: obtaining parts in bulk at a discount but charging the government full price. The United States District Court for the Northern District of Texas dismissed the plaintiff’s suit for lack of subject matter jurisdiction, ruling that the FCA’s “first-to-file” bar applied because the earlier action covered the same essential elements of fraud.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision. The appellate court found that the two complaints alleged distinct fraudulent schemes: one involving bulk pricing manipulation, and the other involving the submission of inflated subcontractor cost data. The Fifth Circuit held that the first-to-file bar under the FCA did not apply because the plaintiff’s complaint was based on a different mechanism of fraud, not merely additional details or locations of the same scheme. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Ferguson v. Lockheed Martin" on Justia Law

Several employees of United Airlines challenged the company's COVID-19 vaccine mandate, alleging that United failed to provide reasonable religious and medical accommodations, in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). United required all U.S. employees to be vaccinated by specific deadlines unless granted a religious or medical exemption. Employees seeking a religious accommodation needed to provide a personal statement of belief and a third-party attestation; those seeking a medical exemption had to submit supporting medical documentation. United initially planned to place all exempted employees on unpaid leave but later revised its policy for non-customer-facing employees, allowing them to work with masking and testing requirements, while customer-facing employees remained on indefinite unpaid leave.The United States District Court for the Northern District of Texas considered and partially granted the plaintiffs’ motion for class certification. The district court rejected a class seeking injunctive relief under Rule 23(b)(2) and a subclass of employees subject to masking and testing requirements, finding that the proposed classes lacked commonality and predominance due to the individualized nature of harm and the need for separate inquiries into the circumstances of each member. The court certified a modified subclass under Rule 23(b)(3) consisting of religious-accommodation seekers who were placed on unpaid leave but excluded those with medical accommodations from the subclass.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the class certification order under an abuse of discretion standard. The Fifth Circuit affirmed the district court’s decision, holding that the district court did not abuse its discretion in rejecting the broader classes and subclasses due to the individualized nature of the claims and in certifying the subclass of religious-accommodation seekers placed on unpaid leave. The court found that common questions predominated and that a class action was a superior method of adjudication for that subclass. View "Sambrano v. United Airlines" on Justia Law

A maritime worker was injured while unloading cargo from a vessel managed by Grieg Star AS. The worker, employed by a stevedoring company, fell ten feet when she stepped onto plastic sheeting covering a gap between rolls of cargo in the ship’s hold. The cargo, consisting of large rolls of kraft liner board, had been loaded by longshoremen overseas, and plastic sheeting was used to cover gaps between layers. The injured worker had been assigned to roll up this sheeting during the final phase of unloading. She was aware of the gaps but alleged that the plastic concealed them and appeared to provide fall protection.After the accident, the worker filed a suit in Texas state court against Grieg Star, alleging vessel negligence under the Longshore and Harbor Workers’ Compensation Act, specifically violations of the turnover and active control duties. The case was removed to the United States District Court for the Southern District of Texas. Following discovery, Grieg Star moved for summary judgment, arguing there was no genuine dispute of material fact and that it was entitled to judgment as a matter of law. The district court agreed and granted summary judgment in favor of Grieg Star. The worker appealed.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. It held that the alleged hazard was open and obvious to the worker, so the vessel owed no turnover duty to warn. The court also found that Grieg Star did not exercise active control over the stevedoring operations or the area where the injury occurred, as the stevedore had responsibility for the hold at the time. Accordingly, the Fifth Circuit affirmed the district court’s grant of summary judgment to Grieg Star. View "Renteria v. Grieg Star AS" on Justia Law

The defendant was charged with possessing a firearm after having been convicted of felonies, including drug trafficking and DUI. At the time he allegedly possessed the firearm, he was on supervised release for the DUI offense. He was indicted under 18 U.S.C. § 922(g)(1), which prohibits firearm possession by felons. The defendant moved to dismiss the indictment, arguing that § 922(g)(1) was unconstitutional on multiple grounds. After the district court denied his motion, he pleaded guilty while preserving his right to appeal the constitutional issues.The United States District Court for the Southern District of Mississippi denied the defendant’s motion to dismiss the indictment, rejecting his constitutional challenges to § 922(g)(1). Following his guilty plea, the defendant appealed, raising several arguments: that the statute was unconstitutional under the Second Amendment (both facially and as applied), violated Equal Protection, exceeded Congress’s authority under the Commerce Clause, and was unconstitutionally vague. The court noted that Fifth Circuit precedent foreclosed all arguments except the vagueness challenge.The United States Court of Appeals for the Fifth Circuit reviewed the preserved vagueness challenge de novo. The court held that § 922(g)(1) is not void for vagueness, emphasizing that the statute clearly defines the prohibited conduct—possession of a firearm by a felon. The court further held that recent developments in Second Amendment jurisprudence, including New York State Rifle & Pistol Association v. Bruen and United States v. Diaz, did not render the statute vague in the defendant’s case, as these precedents did not affect the clarity of the statutory language or create confusion for ordinary persons. Accordingly, the Fifth Circuit affirmed the conviction. View "United States v. Landrum" on Justia Law

A federal law enforcement officer was charged following two separate incidents that took place at a U.S. border crossing. In the first, the officer confronted an individual, Espinosa, who had been involved in a verbal disagreement with another officer. The officer intervened, physically redirected Espinosa, and both collided with a door, resulting in Espinosa experiencing physical injuries such as dizziness and confusion. Testimony from a supervisor and an expert witness indicated the force used was excessive and not justified by Espinosa’s behavior at the time. In the second incident, the officer engaged with Estrada, a returning traveler, following a verbal exchange. The officer brought Estrada into a secure area, used force to restrain him, and pressed his face into chairs, causing a nose injury. Witnesses and expert testimony again described the officer’s actions as excessive and unnecessary, and video evidence did not show Estrada acting aggressively or resisting.After these events, the officer filed a report about the Estrada incident, which contained statements that were contradicted by video evidence and expert analysis. The officer also made verbal statements to a supervisor that were later found to be false.The United States District Court for the Western District of Texas conducted a bench trial, found the officer guilty of two counts of deprivation of rights under color of law (18 U.S.C. § 242) and one count of falsifying a record in a federal investigation (18 U.S.C. § 1519), and imposed concurrent sentences below the guidelines. The officer appealed, challenging the sufficiency of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a highly deferential standard to the verdict. The court held that a rational factfinder could find all elements of the crimes proven beyond a reasonable doubt and affirmed the convictions. View "United States v. Delgado" on Justia Law