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

A group of Indian nationals, legally present in the United States on employment-based visas, filed a lawsuit against the Secretary of State and the Director of U.S. Citizenship and Immigration Services (USCIS). The plaintiffs were seeking permanent residency and challenged the defendants' approach to distributing immigrant visas. They argued that the defendants' policies of deferring adjudication of their applications until a visa number becomes available violated the statute governing adjustment of status for nonimmigrants. They sought injunctive and declaratory relief under the Administrative Procedure Act and the federal Declaratory Judgment Act.The plaintiffs had initially moved for a preliminary injunction in the United States District Court for the Eastern District of Texas, but their motion was denied. They appealed this decision to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit, however, found that it lacked subject-matter jurisdiction to hear the case. The court cited the Immigration and Nationality Act (INA), which strips federal courts of jurisdiction to address many challenges brought in the context of immigration proceedings. The court concluded that the INA's jurisdiction-stripping provisions precluded it from hearing the plaintiffs' challenge. The court vacated the district court's decision and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "Cheejati v. Blinken" on Justia Law

The estate and heirs of Dale O'Neal, a pre-trial detainee who was murdered by his cellmate in Clay County's jail, filed a lawsuit against several officers and the county under Section 1983. They alleged that the defendants failed to protect O'Neal, thereby violating his Fourteenth Amendment rights. The case centered around the actions of the intake officer, Annie Avant, who assigned O'Neal's murderer, Cameron Henderson, to the same cell as O'Neal. The parties disputed what information was conveyed to Avant about Henderson's violent behavior and whether the booking system would have revealed that Henderson was previously determined to be a threat.The district court agreed with the magistrate judge's decision to exclude a late-designated expert and the accompanying report, which the plaintiffs relied on to establish the County's liability. The court then granted summary judgment to all defendants, concluding that the plaintiffs could not create a fact question as to whether the individual defendants acted with deliberate indifference. The court also found that Avant had qualified immunity.On appeal to the United States Court of Appeals for the Fifth Circuit, the plaintiffs argued that it was an abuse of discretion to exclude the expert and error to grant summary judgment to Avant. The appellate court affirmed the lower court's decision. It found no abuse of discretion in excluding the late-designated expert, considering factors such as the explanation for the failure to identify the witness, the importance of the testimony, potential prejudice in allowing the testimony, and the availability of a continuance to cure such prejudice. The court also affirmed the grant of summary judgment to Avant on the basis of qualified immunity, noting that the plaintiffs failed to point to any case supporting the proposition that the alleged constitutional violation was of clearly established law. View "Culberson v. Clay County" on Justia Law

A group of business associations, including the Fort Worth Chamber of Commerce, filed a lawsuit in the Northern District of Texas against the Consumer Protection Financial Bureau (CFPB). The plaintiffs challenged a new Final Rule issued by the CFPB regarding credit card late fees and sought a preliminary injunction against the rule. The plaintiffs requested expedited briefing and review due to the imminent effect of the rule and the substantial compliance it required.The district court, instead of ruling on the motion for a preliminary injunction, considered whether venue was appropriate in the Northern District of Texas and invited the CFPB to file a motion to transfer the case. The CFPB complied, and the district court granted its motion, transferring the case to the United States District Court for the District of Columbia. The plaintiffs then petitioned for a writ of mandamus, arguing that the district court abused its discretion by transferring the case while their appeal was pending and, alternatively, lacked jurisdiction to transfer the case.The United States Court of Appeals for the Fifth Circuit agreed with the plaintiffs, stating that the district court acted without jurisdiction. The court explained that once a party properly appeals something a district court has done, in this case, the effective denial of a preliminary injunction, the district court has no jurisdiction to do anything that alters the case’s status. The court clarified that its decision was not about the correctness of the district court’s transfer order but rather about whether the court had jurisdiction to enter it. The court concluded that the district court did not have jurisdiction to transfer the case.The court granted the petition for mandamus, vacated the district court’s transfer order, and ordered the district court to reopen the case. The court also instructed the district court to notify the District of Columbia that its transfer was without jurisdiction and should be disregarded. View "In re: Chamber of Commerce" on Justia Law

Courtney D. Clayton was indicted on one count of possession with intent to distribute heroin, fentanyl, and cocaine. As part of a three-month drug trafficking investigation, officers conducted video surveillance of Clayton's home and placed GPS tracking devices on two vehicles associated with him. Based on the surveillance and information from a reliable confidential informant, officers obtained search warrants for Clayton's home and one of his vehicles. However, before the warrants could be executed, officers observed burglars break into Clayton's home. Believing that evidence of drug trafficking may have been stolen, officers continued their investigation for another two weeks before seeking a new warrant for Clayton's residence. The officers did not renew their search warrant for the vehicle.The district court denied Clayton's motion to suppress evidence found in his vehicle and his incriminating statement to law enforcement. Clayton contended that the search warrant of the vehicle had become stale, and that officers did not have probable cause to arrest him. He also argued that the Government failed to show that officers advised him of his constitutional rights pursuant to Miranda v. Arizona. After the denial of his motion to suppress, Clayton pleaded guilty but preserved his right to appeal the denial of his motion to suppress.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the search of Clayton's vehicle was proper under the automobile exception to the Fourth Amendment, which allows a warrantless search of a readily mobile vehicle when law enforcement has probable cause to believe the vehicle contains contraband or evidence of a crime. The court also found that Clayton failed to properly invoke his Fifth Amendment right to silence, as his indication through body language that he did not wish to speak to officers did not constitute a "simple, unambiguous statement" invoking his right to remain silent. View "United States v. Clayton" on Justia Law

In this case, a government agency had approved a license to construct and operate a massive deepwater oil facility off the coast of Texas. Several environmental organizations alleged that the approval was unreasonable, arguing that the agency failed to adequately support its decision with a thorough environmental impact analysis. The groups claimed this was in violation of the Deepwater Port Act and the National Environmental Policy Act. They contended that the agency's approval was arbitrary or capricious. The environmental organizations asserted that operating the facility would produce emissions equivalent to more than 80 new coal-fired power plants and could increase the likelihood of mass oil spills along miles of the Texas coastline. They also voiced concerns about potential threats to the Gulf's marine environment.After their concerns were initially dismissed by the agency overseeing the project, the environmental organizations appealed the licensing decision. They claimed the agency had not conducted the appropriate level of review in its environmental impact statement and had not followed relevant statutory provisions during the approval process.The United States Court of Appeals for the Fifth Circuit held that the agency had adequately considered the environmental consequences of the facility before approving its deepwater port license. The court found that the agency's decision was not arbitrary or capricious, and as such, it denied the petition for review brought by the environmental organizations. The court ruled that the agency had taken a "hard look" at the environmental consequences of the project, provided sufficient detail for the public to understand and consider the relevant environmental influences, and evaluated alternatives in a way that permitted a reasoned choice among different courses of action. View "Citizens for Clean Air & Clean Water in Brazoria County v. United States Department of Transportation" on Justia Law

The case revolves around Susan Miller, who sued Michaels Stores, Inc. for negligence after she slipped and fell in one of their stores in Slidell, Louisiana, during a rainstorm. Miller claimed that she had entered the store via a propped-open exit door, where no warning signs or mats were present, and subsequently slipped on a clear substance. She argued that a store employee had admitted to the presence of a warning sign and mat at the other door, indicating that the store was aware of the wet conditions but had failed to adequately warn customers.Earlier, the United States District Court for the Eastern District of Louisiana had granted summary judgment in favor of Michaels. The store had argued that Miller lacked evidence proving that they had notice of any hazards where she slipped. The district court ruled that none of the evidence showed that Michaels was aware of a hazard in the area where Miller fell, and hence granted summary judgement for Michaels.Upon review by the United States Court of Appeals for the Fifth Circuit, the court affirmed the district court’s decision. The court held that Miller's evidence was insufficient to show that Michaels had actual or constructive notice of the specific hazard that caused her fall. Furthermore, it ruled that the statements made by the Michaels employee were irrelevant to the issue of notice and were therefore inadmissible. Lastly, the court found no evidence that Michaels had spoiled any evidence, as alleged by Miller. Therefore, the court affirmed the summary judgment in favor of Michaels Stores. View "Miller v. Michaels Stores" on Justia Law

The case revolves around a dispute between the Career Colleges and Schools of Texas (CCST) and the United States Department of Education over new regulations that will facilitate certain student loan discharges. The contested rule overturns recent regulations issued by the previous administration and alters thirty years of regulatory practice. The CCST challenged the regulations, arguing that they create uncertainty and potentially significant liability for its members. The district court declined to issue a preliminary injunction against the rule, stating that the plaintiffs had not demonstrated irreparable harm.CCST argued that the new regulations are beyond the Department of Education's statutory authority, violate the Administrative Procedure Act (APA), and infringe on the due process rights of its members. The United States Court of Appeals for the Fifth Circuit disagreed with the lower court's findings, concluding that CCST is likely to succeed on the merits of its challenge and that its members will face immediate and irreparable harm if the new regulations are allowed to go into effect.The court reversed the district court's judgment and remanded the case with instructions to enjoin and postpone the effective date of the challenged provisions pending final judgment. The court ruled that the Department of Education's new regulations are likely unlawful and that their implementation would cause immediate and irreparable harm to CCST and its members. The court ordered the lower court to issue a preliminary injunction to delay the implementation of the new regulations until the case is finally resolved. View "Career Colleges and Schools of Texas v. United States Department of Education" on Justia Law

A group of individuals, including D&T Partners LLC and ACET Global LLC, alleged that Baymark Partners Management LLC and others attempted to steal the assets and trade secrets of their e-commerce company through shell entities, corrupt lending practices, and a fraudulent bankruptcy. The plaintiffs claimed that Baymark had purchased D&T's assets and then defaulted on its payment obligations. According to the plaintiffs, Baymark replaced the company's management, caused the company to default on its loan payments, and transferred the company's assets to another entity, Windspeed Trading LLC. The plaintiffs alleged that this scheme violated the Racketeer Influenced and Corrupt Organizations Act (RICO).The case was initially heard in the United States District Court for the Northern District of Texas. The district court dismissed all of the plaintiffs' claims with prejudice, finding that the plaintiffs were unable to plead a pattern of racketeering activity, a necessary element of a RICO claim.The case was then taken to the United States Court of Appeals for the Fifth Circuit. The appellate court agreed with the district court, holding that while the complaint alleges coordinated theft, it does not constitute a "pattern" of racketeering conduct sufficient to state a RICO claim. This is because the alleged victims were limited in number, and the scope and nature of the scheme was finite and focused on a singular objective. Therefore, the appellate court affirmed the district court’s judgment. View "D&T Partners v. Baymark Partners" on Justia Law

Highland Capital Management, L.P., a firm co-founded by James Dondero, filed for bankruptcy in 2019 due to litigation claims. As part of a settlement agreement, Dondero relinquished control of Highland to three independent directors, one of whom, James P. Seery, was appointed as Highland’s Chief Executive Officer, Chief Restructuring Officer, and Foreign Representative by the bankruptcy court. To protect Seery from vexatious litigation, the bankruptcy court issued an order that no entity could commence or pursue a claim against Seery relating to his role without the bankruptcy court's prior approval. Despite this, two entities founded by Dondero, the Charitable DAF Foundation and its affiliate CLO Holdco, filed a lawsuit against Highland in district court, alleging that Highland, through Seery, had withheld material information and engaged in self-dealing related to a settlement with one of its largest creditors, HarbourVest.The bankruptcy court held the appellants in civil contempt for violating its order and ordered them to pay $239,655 in compensatory damages. The district court affirmed the bankruptcy court's decision, concluding that the award was compensatory and therefore civil. The appellants appealed to the United States Court of Appeals for the Fifth Circuit, arguing that the sanction was punitive and thus exceeded the scope of the bankruptcy court’s civil contempt powers.The United States Court of Appeals for the Fifth Circuit vacated the district court's decision and remanded the case. The appellate court found that the bankruptcy court had abused its discretion by imposing a punitive sanction that exceeded its civil contempt powers. The court held that the sanction was not compensatory because it was not based on the damages Highland suffered due to the appellants' decision to file the motion in the wrong court. The court instructed the bankruptcy court to limit any sanction award to the damages Highland suffered because of this error. View "Charitable DAF Fund v. Highland Captl Mgmt" on Justia Law

This case involves a dispute between Sheet Pile, LLC and Plymouth Tube Company. The conflict arose from an exclusivity agreement, in which Plymouth agreed to manufacture certain products only for PilePro, Sheet Pile's predecessor. Approximately a decade later, Sheet Pile accused Plymouth of breaching this agreement by selling those products to other companies, and they sued for fraud and breach of contract. The district court granted summary judgment in favor of Plymouth.Sheet Pile then appealed. The Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the lower court's decision. For the breach-of-contract claim, the court concluded that the claim was time-barred under Texas law, which has a four-year statute of limitations for such claims. The court also held that the discovery rule, which could have deferred the accrual of the cause of action, did not apply.Regarding the fraud claim, the court concluded that Sheet Pile failed to demonstrate a genuine dispute of material fact that Plymouth's representations were false when made. The court noted that there was no evidence that Plymouth sold the exclusive products to third parties in 2014 or 2015, and that Plymouth had expressly warned PilePro that it might begin selling to third parties if PilePro didn't hold up its end of the agreement. Therefore, the court affirmed summary judgment for Plymouth. View "Sheet Pile v. Plymouth Tube" on Justia Law