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

Quincy Palmer was stopped by Houston Police officers for driving with a tinted windshield, which is illegal under Texas law. During the stop, Palmer admitted to possessing marijuana and a firearm, and also revealed that he was a convicted felon. Palmer moved to suppress the evidence obtained during the stop, arguing that the officers lacked reasonable suspicion to stop him and that his statements should be suppressed under Miranda v. Arizona.The United States District Court for the Southern District of Texas denied Palmer’s motion to suppress. The court found that the officers had reasonable suspicion to stop Palmer based on the illegal tint on his windshield. Additionally, the court determined that Palmer’s statements were not made during a custodial interrogation, and thus, Miranda warnings were not required. Palmer subsequently pleaded guilty to possession of a firearm by a felon but reserved the right to appeal the suppression ruling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the officers had reasonable suspicion to stop Palmer due to the illegal windshield tint, which was corroborated by video evidence and officer testimony. The court also upheld the finding that Palmer was not in custody for Miranda purposes when he made the incriminating statements, as the interaction was brief, non-accusatory, and occurred in a public setting. Therefore, the court concluded that there was no Miranda violation and affirmed the denial of Palmer’s motion to suppress. View "United States v. Palmer" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law

In February 2023, state detectives in Midland, Texas, arranged a controlled purchase of cocaine from Samuel Barraza-Urias. During a traffic stop, officers found Barraza-Urias and Bay Travon Wilson in a vehicle with 160.6 grams of cocaine and three firearms, including a short barrel AR-15 rifle, a KelTec semi-automatic pistol, and a Ruger semi-automatic pistol with an obliterated serial number. Wilson admitted to possessing the rifle and the KelTec pistol. He pleaded guilty to being a felon in possession of a firearm and possessing an unregistered firearm.The United States District Court for the Western District of Texas assigned Wilson a base offense level of 20 and applied several enhancements: a four-level enhancement for possessing a firearm in connection with another felony offense, a four-level enhancement for possessing a firearm with an obliterated serial number, and a two-level enhancement for possession of three or more firearms. Wilson objected to these enhancements, arguing insufficient evidence. The district court overruled his objections and sentenced him to 97 months’ imprisonment and three years of supervised release on each count, to run concurrently.The United States Court of Appeals for the Fifth Circuit reviewed the case. Wilson argued that his conviction under 18 U.S.C. § 922(g)(1) violated his Second Amendment rights post-Bruen. The court reviewed for plain error and found no clear or obvious error. The court also upheld the district court’s application of the sentencing enhancements, finding sufficient evidence that Wilson was involved in drug trafficking and constructively possessed the Ruger pistol. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Wilson" on Justia Law

Patrick and Patricia McConathy filed for bankruptcy in Louisiana in 1990 but failed to disclose their interests in over 3,000 acres of land in Kansas. In 2019, the McConathys and other plaintiffs sued American Warrior, Inc. (AWI) in Kansas state court over these interests. During discovery, AWI learned of the McConathys' undisclosed bankruptcy and moved to reopen the bankruptcy case in 2021. The bankruptcy court reopened the case and imposed an automatic stay on the Kansas litigation.The bankruptcy court found that the McConathys and their attorneys violated the automatic stay by continuing the Kansas litigation but did not find that the non-debtor plaintiffs violated the stay. The court later approved a settlement between AWI and the bankruptcy trustee, transferring the estate's interests to AWI. Subsequently, the bankruptcy court terminated the automatic stay concerning the non-debtor plaintiffs and decided to permissively abstain from the Kansas litigation, allowing it to proceed in state court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the bankruptcy court did not err in its decisions. It affirmed that the Kansas litigation was not void ab initio and that the non-debtor plaintiffs did not violate the automatic stay. The court also upheld the bankruptcy court's decision to terminate the stay and abstain from the Kansas litigation, emphasizing that the bankruptcy court had broad discretion to modify or lift the stay as circumstances changed. The Fifth Circuit concluded that it lacked jurisdiction to review the bankruptcy court's permissive abstention decision, affirming the lower courts' rulings. View "American Warrior v. Foundation Energy" on Justia Law

The case involves tanker-truck drivers employed by Ace Gathering, Inc., who transport crude oil solely within Texas. The drivers, known as Crude Haulers, collect crude oil from oil fields and deliver it to pipeline injection points. Although their routes are entirely within Texas, a significant portion of the crude oil they transport is ultimately destined for out-of-state refineries or export markets. The drivers claim they worked over forty hours a week without receiving overtime pay, alleging they were misclassified as exempt from the Fair Labor Standards Act (FLSA) overtime provisions.The United States District Court for the Southern District of Texas initially denied Ace's motion for summary judgment, which argued that the Motor Carrier Act (MCA) exempted the Crude Haulers from FLSA overtime pay. The district court found that Ace had no vested interest in the crude oil once it crossed state lines and that the volunteer-based interstate driving assignments created a genuine dispute of material fact regarding the drivers' reasonable expectation of interstate travel. Upon reconsideration, the district court certified three questions for interlocutory appellate review.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the Crude Haulers' transportation of crude oil within Texas constitutes transportation in "interstate or foreign commerce" under the MCA because the oil is ultimately bound for out-of-state destinations. The court noted that the intrastate transport of goods destined for out-of-state locations falls under the MCA's definition of interstate commerce. Consequently, the court reversed the district court's denial of summary judgment and remanded the case with instructions to dismiss the plaintiffs' claims with prejudice. View "Escobedo v. Ace Gathering" on Justia Law

Balboa Capital Corporation, a financing company, entered into agreements with various physicians across multiple states to finance their participation in a telehealth program run by America’s Medical Home Team (MHT). MHT, however, was operating a Ponzi scheme and failed to deliver the promised services and equipment. Balboa financed the physicians' participation by paying MHT directly and then sought repayment from the physicians through monthly payment agreements (MPAs) or installment payment agreements (IPAs). The physicians, unaware of the full terms and believing they could withdraw without financial obligations, defaulted on their payments after MHT's collapse.The United States District Court for the Northern District of Texas consolidated multiple collection actions filed by Balboa against the physicians. The court struck an evidentiary exhibit that combined the payment agreements with invoices, ruling that the invoices were not properly authenticated and constituted impermissible hearsay. The court then granted summary judgment in favor of the physicians, finding that the payment agreements alone did not constitute valid contracts as they lacked essential terms such as the total amount financed and the cost of financing.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s rulings. The appellate court affirmed the decision to strike the exhibit, agreeing that the invoices were not properly authenticated and did not meet the business records exception to the hearsay rule. The court also affirmed the summary judgment, holding that the payment agreements, even if considered together with the invoices, did not form enforceable contracts under California law due to the absence of material terms. Consequently, Balboa’s claims for breach of contract and breach of guarantee failed as a matter of law. View "Balboa Capital v. Okoji Home Visits MHT, L.L.C." on Justia Law

Karl Von Derhaar, an employee at the New Orleans Crime Lab, raised concerns about safety breaches and inaccuracies in a drug-testing method. Instead of addressing these concerns, the Lab mandated that all employees, including Von Derhaar, be tested using the disputed method. Von Derhaar requested unpaid leave, and his supervisor, Sergeant Michael Stalbert, attempted to contact him at home. After initially going to the wrong apartment, Stalbert returned with two armed officers. Von Derhaar, standing in his doorway, declined to speak with Stalbert, who then forcibly entered the apartment, claiming it was a wellness check. Despite no visible signs of distress, Stalbert ordered Von Derhaar out of his home, where another supervisor, Lieutenant Kim Williams, awaited. Von Derhaar was then taken to the Police Integrity Bureau (PIB) headquarters against his will.The United States District Court for the Eastern District of Louisiana reviewed the case. The court granted summary judgment to the City of New Orleans and its police superintendent on all claims, finding no municipal liability. On the search claim, the court granted summary judgment to Williams and Officer Khalid Watson but denied it to Stalbert. On the seizure claim, the court denied summary judgment to Stalbert, Williams, and Khalid Watson. These decisions led to the current appeals and cross-appeals.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court dismissed the appeals regarding the denial of summary judgment to Stalbert on punitive damages, the summary judgment to Khalid Watson on the search claim, and the summary judgment to the City and superintendent. The court affirmed the denial of summary judgment to Stalbert on the search and seizure claims, finding material fact disputes. However, it reversed the denial of summary judgment to Williams and Khalid Watson on the seizure claim, concluding that they acted under orders and did not violate clearly established law. The case was remanded for further proceedings. View "Von Derhaar v. Watson" on Justia Law

The Department of Transportation (DOT) issued a Rule on April 30, 2024, requiring airlines to disclose ancillary service fees, such as baggage and change fees, during the booking process. The Rule aims to protect consumers from surprise charges and is expected to provide significant societal and consumer benefits. The Rule took effect on July 1, 2024, with compliance deadlines for airlines and third-party ticket agents set for later dates. Various airlines and airline associations challenged the Rule, arguing it exceeds DOT’s authority, is arbitrary and capricious, and bypassed the required notice and comment process.The airlines and associations first sought a stay from the DOT, which was denied. They then petitioned the United States Court of Appeals for the Fifth Circuit for a stay pending review. The petitioners argued that the Rule exceeds DOT’s statutory authority under 49 U.S.C. § 41712(a), which allows the DOT Secretary to investigate and adjudicate unfair or deceptive practices but does not authorize the creation of detailed legislative rules. The petitioners also claimed that the Rule imposes significant compliance costs that would cause irreparable harm.The United States Court of Appeals for the Fifth Circuit granted the stay, finding that the petitioners made a strong showing that the Rule likely exceeds DOT’s authority. The court noted that the Rule mandates specific disclosure practices without the adjudicatory process required by the statute. The court also found that the petitioners would suffer irreparable harm due to the nonrecoverable compliance costs. The court concluded that there is no public interest in perpetuating unlawful agency action and expedited the petition for review to the next available oral argument panel. View "Airlines for America v. Department of Transportation" on Justia Law

Keiland Construction, L.L.C. entered into a construction subcontract with Weeks Marine, Inc. for a project in Louisiana. Weeks terminated the contract for convenience, leading to a dispute over compensation. Keiland submitted pay applications and demobilization costs, which Weeks partially paid. The disagreement centered on whether the contract required lump-sum payments for work completed before termination or if it converted to a cost-plus basis upon termination.The United States District Court for the Western District of Louisiana held a bench trial and found the contract ambiguous. It construed the ambiguity against Keiland, the drafter, and ruled in favor of Weeks. The court awarded Keiland damages based on Weeks’s interpretation of the contract but denied Keiland’s claims for direct employee and demobilization costs. The court also awarded Weeks attorneys’ fees and costs, though less than requested, and denied Weeks’s motion for post-offer-of-judgment fees and costs.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s findings, agreeing that the contract was ambiguous and that the ambiguity should be construed against Keiland. The appellate court upheld the district court’s rulings on damages, attorneys’ fees, and costs, including the denial of post-offer-of-judgment fees and costs. The court also affirmed the award of prejudgment interest to Keiland, finding no abuse of discretion.In summary, the Fifth Circuit affirmed the district court’s judgment in all respects, including the interpretation of the contract, the award of damages, attorneys’ fees, costs, and prejudgment interest. View "Keiland Construction v. Weeks Marine" on Justia Law

The case involves a dispute between the law firm Abraham Watkins Nichols Agosto Aziz & Stogner and its former associate, Edward Festeryga. Abraham Watkins terminated Festeryga’s employment after discovering that he attempted to take clients and firm files to a new firm. Abraham Watkins sued Festeryga in Texas state court for conversion, breach of fiduciary duty, and tortious interference with contract. Festeryga moved to dismiss the suit under Texas’s anti-SLAPP statute, the Texas Citizens Participation Act (TCPA), which stayed the expedited discovery sought by Abraham Watkins. Despite agreeing to produce certain documents, Festeryga filed a notice of removal to federal court, claiming diversity jurisdiction as a Canadian citizen.The United States District Court for the Southern District of Texas remanded the case back to state court. The district court did not address whether Festeryga had shown diversity of citizenship but concluded that Festeryga waived his right to remove by participating in state court proceedings, specifically by filing a TCPA motion to dismiss. The district court found that this action demonstrated an intent to invoke the jurisdiction of the state court.The United States Court of Appeals for the Fifth Circuit reviewed the case to determine if it had appellate jurisdiction over the remand order. The court concluded that it did not have jurisdiction, citing its precedent in In re Weaver, which held that waiver-based remand orders are jurisdictional under 28 U.S.C. § 1447(c) and thus unappealable under § 1447(d). The court noted that although it disagreed with the reasoning in Weaver, it was bound by the rule of orderliness to follow the precedent. Consequently, the Fifth Circuit dismissed the appeal for lack of appellate jurisdiction. View "Abraham Watkins Nichols Agosto Aziz & Stogner v. Festeryga" on Justia Law