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

Amazon.com Services LLC appealed the "constructive denial" of its motion for injunctive relief from two administrative proceedings before the National Labor Relations Board (NLRB). The case involves Amazon's fulfillment center in Staten Island, New York, where the Amazon Labor Union (ALU) won an election to represent over 8,000 employees. Amazon filed objections alleging interference by ALU and the NLRB's Regional Office, leading to two NLRB cases: one concerning the election and another regarding Amazon's refusal to bargain with ALU.The United States District Court for the Western District of Texas reviewed Amazon's request for temporary, preliminary, and permanent declaratory and injunctive relief to avoid harm from the alleged unconstitutional proceedings. Amazon argued that the structure of the NLRB proceedings violated the U.S. Constitution. The district court denied Amazon's request for a temporary restraining order, finding that Amazon had not established a substantial threat of irreparable harm. The court also granted but stayed the NLRB's motion to transfer the case to the Eastern District of New York.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court found that Amazon did not act diligently in seeking expedited relief and failed to establish a legitimate basis for urgency. The court noted that Amazon did not repeatedly request swift review or a ruling by a specific date until the day before its deadline to respond to the NLRB's summary judgment motion. The court concluded that the district court did not effectively deny Amazon's motion for injunctive relief by failing to rule by September 27, 2024. Consequently, the Fifth Circuit dismissed the appeal for lack of subject-matter jurisdiction. View "Amazon.com v. National Labor Relations Board" on Justia Law

The case involves a dispute arising from alleged breaches of a partnership agreement between PNC Bank, N.A., Columbia Housing SLP Corporation (collectively, the "PNC Parties"), and Rene O. Campos, along with 2013 Travis Creek GP, LLC, as general partner. The partnership was formed to acquire, construct, develop, and operate an affordable housing apartment complex in Austin, Texas, with anticipated federal tax credits. A mechanic’s lien was placed on the property, leading to a default on the construction loan. The PNC Parties sought to remove the general partner and replace it with Columbia, resulting in a lawsuit.The PNC Parties filed the lawsuit in the United States District Court for the Western District of Texas, invoking diversity jurisdiction. The district court retained supplemental jurisdiction over the enforcement of the settlement agreement that resolved the 2017 lawsuit. In 2021, the Eureka Parties moved to re-open the case to enforce the settlement agreement, leading to competing motions to enforce. The district court severed the motions from the original lawsuit, creating a new case, and granted each motion in part, offsetting the balance owed. The Eureka Parties and the Partnership appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the parties failed to establish an independent jurisdictional basis for the severed motions. The court noted that severed claims must have an independent jurisdictional basis and that the record lacked sufficient evidence to establish diversity of citizenship. Consequently, the court remanded the case to the district court for the limited purpose of determining whether such jurisdiction exists. The panel retained jurisdiction over the limited remand. View "PNC Bank v. 2013 Travis Oak Creek" on Justia Law

The case involves the Texas Public Policy Foundation (TPPF) filing a Freedom of Information Act (FOIA) request with the U.S. Department of State. TPPF sought records related to the development of the United States' 2030 emissions reduction target under the Paris Agreement, including the names and email addresses of State Department employees involved. The State Department redacted the names and email addresses, citing FOIA Exemption 6, which protects against unwarranted invasions of personal privacy.The U.S. District Court for the Western District of Texas granted summary judgment in favor of the State Department, agreeing that the redacted information fell under Exemption 6. The court found that disclosing the names and email addresses of lower-level employees would not advance public understanding of the government's operations and could subject the employees to harassment.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the State Department did not meet its burden of proving that the privacy interests of its employees clearly outweighed the public's interest in disclosure. The court found that the public has a right to know who participated in developing the emissions reduction target and that the employees' privacy interests were not significant enough to justify withholding their names and email addresses. The court reversed the district court's decision and rendered judgment in favor of TPPF, requiring the State Department to disclose the requested information. View "Texas Public Policy v. U.S. Dept. of State" on Justia Law

Anthology, Inc. entered into a 10-year contract with Tarrant County College District (TCCD) in June 2022 to provide Enterprise Resource Planning products and services for approximately $42 million, plus annual fees. In October 2023, TCCD terminated the contract without cause, as permitted by the contract, but refused to pay the early termination fee and demanded a refund of about $1.7 million already paid. Anthology sued TCCD in the United States District Court for the Northern District of Texas, seeking a declaratory judgment and damages for breach of contract.TCCD moved to dismiss the case under Federal Rules 12(b)(1) and 12(b)(6), arguing four grounds: entitlement to immunity from suit under Texas law, state sovereign immunity, lack of diversity jurisdiction, and a statutory bar on recovering damages under Texas law. The district court granted TCCD’s Rule 12(b)(1) motion, dismissing Anthology’s claims without prejudice, based on TCCD’s entitlement to immunity from suit under Texas law, without addressing the other grounds for dismissal. Anthology appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court erred in its decision. The appellate court held that state-law immunity cannot limit the jurisdiction of federal courts, which is defined by the Constitution and Congress. Therefore, the district court should not have dismissed the case based on state-law immunity without first addressing the jurisdictional issues of state sovereign immunity and the absence of complete diversity. The Fifth Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Anthology v. Tarrant County College District" on Justia Law

Customs and Border Protection officers seized a tractor-trailer at the Columbia Solidarity Bridge Port of Entry in Laredo, Texas, which was carrying liquid methamphetamine concealed in the fuel tanks. Noe de Jesus Martinez-Montelongo was driving the vehicle, and Fidel Saldana Rodriguez was the passenger. Both were convicted by a jury of conspiracy to import and importation of methamphetamine. Saldana challenged the sufficiency of the evidence for his convictions, while Martinez-Montelongo challenged the substantive reasonableness of his sentence.The United States District Court for the Southern District of Texas denied both defendants' motions for judgment of acquittal and sentenced them to 235 months of imprisonment each. Saldana argued on appeal that the evidence was insufficient to prove he knew about the methamphetamine, while Martinez-Montelongo argued that his sentence was unreasonable because the district court improperly considered his failure to admit guilt.The United States Court of Appeals for the Fifth Circuit reviewed Saldana's sufficiency challenge de novo and found that the evidence, including inconsistent statements, the use of a stick to measure fuel levels, and WhatsApp messages, was sufficient for a reasonable jury to conclude that Saldana knowingly participated in the conspiracy. The court affirmed Saldana's convictions.Regarding Martinez-Montelongo's sentence, the court found that the district court did not rely on his lack of remorse in its § 3553(a) analysis. The district court's references to the defendants' insistence on innocence were to explain why they were being sentenced and why they were not eligible for certain sentencing reductions. The Fifth Circuit concluded that the district court did not abuse its discretion and affirmed Martinez-Montelongo's sentence. View "United States v. Martinez-Montelongo" on Justia Law

Roy Lee Jones, Jr. was involved in a methamphetamine-trafficking organization in North-Central Louisiana. He received large shipments of methamphetamine from his California-based supplier, DeLewis Johnson IV, and redistributed them to Willie Todd Harris, who then sold them to street-level dealers. After a ten-month investigation, federal law enforcement initiated grand jury proceedings, resulting in a five-count indictment. Jones was charged under 21 U.S.C. §§ 841(a)(1) and 846 for conspiracy to distribute and possess with intent to distribute methamphetamine.Jones and Johnson were tried as co-defendants and convicted by a jury. The initial presentence report (PSR) calculated Jones' offense level as 37, recommending a Guidelines range of 210-262 months. The district court sentenced Jones to 210 months' imprisonment. Jones appealed his conviction and sentence, which were affirmed by the United States Court of Appeals for the Fifth Circuit. The Supreme Court denied Jones' petition for a writ of certiorari.Jones filed a motion for a sentence reduction under Amendments 821 and 825 of the United States Sentencing Guidelines. The district court denied the motion, finding that Jones was ineligible for a reduction under USSG § 4C1.1(a)(10) because he had received an aggravating role enhancement under § 3B1.1 and had engaged in a continuing criminal enterprise as defined in 21 U.S.C. § 848.The United States Court of Appeals for the Fifth Circuit reviewed the district court's decision for abuse of discretion, its interpretation of the Guidelines de novo, and its findings of fact for clear error. The court held that either receiving a § 3B1.1 adjustment or engaging in a continuing criminal enterprise is sufficient to disqualify a defendant from a sentence reduction under § 4C1.1(a)(10). Since Jones received an aggravating role enhancement, he was ineligible for a reduction. The court affirmed the district court's decision. View "United States v. Jones" on Justia Law

Trinity Energy Services, L.L.C. ("Trinity Energy") and Southeast Directional Drilling, L.L.C. ("Southeast Drilling") were involved in a subcontract for constructing natural gas pipelines. Disputes arose over liability for "stand-by costs" incurred during construction delays. The parties agreed to arbitration, where a panel awarded Southeast Drilling $1,662,000 in stand-by costs from Trinity Energy. Trinity Energy petitioned to vacate the arbitration award, but the district court denied the petition and confirmed the award. Trinity Energy then appealed.The United States District Court for the Northern District of Texas initially denied Trinity Energy's petition to vacate the arbitration award and granted Southeast Drilling's motion to confirm it. Trinity Energy appealed this decision, but the appeal was dismissed as interlocutory by the United States Court of Appeals for the Fifth Circuit. Subsequently, the district court granted Southeast Drilling's cross-motion to confirm the arbitration award, leading to Trinity Energy's timely appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court's order de novo and emphasized the narrow and deferential standard of review for arbitration awards. The court found that the arbitration panel had construed the subcontract and based its decision on its terms, thus not exceeding its authority under 9 U.S.C. § 10(a)(4). The court also rejected Trinity Energy's argument that the panel manifestly disregarded Texas law, noting that "manifest disregard of the law" is not a valid ground for vacatur under the Federal Arbitration Act. Consequently, the Fifth Circuit affirmed the district court's judgment confirming the arbitration award. Southeast Drilling's request for sanctions against Trinity Energy was denied due to procedural deficiencies. View "Trinity Energy Services v. SE Directional Drilling" on Justia Law

Ryan Rose, an electrical technician, sued Nissan North America, Inc. after suffering an electric shock while working at Nissan’s plant in Canton, Mississippi. Rose was employed by Automated Power, Inc., an electrical engineering firm hired by Nissan to repair damaged equipment following an electrical fault. Rose was injured while working in the plant’s A-B tiebreaker cubicle, which he believed was de-energized. However, the cubicle was still energized on one side, leading to his injury.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of Nissan. The court found that Automated Power was an independent contractor and that both Automated Power and Rose knew or should have known about the dangers associated with the work. Under Mississippi law, a premises owner is not liable for injuries to an independent contractor or its employees resulting from known dangers.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Automated Power was indeed an independent contractor and that the company and Rose were aware of the potential dangers. The court concluded that Mississippi Code § 11-1-66 shielded Nissan from liability, as the statute exempts premises owners from liability for injuries to independent contractors or their employees resulting from known dangers. The court found no genuine dispute of material fact regarding Automated Power’s knowledge of the danger, thus affirming the summary judgment in favor of Nissan. View "Rose v. Nissan North America" on Justia Law

Defendants Louis Age Jr., Louis Age III, Stanton Guillory, and Ronald Wilson were convicted and sentenced to life imprisonment for their roles in the murder-for-hire of Milton Womack, a federal witness in a healthcare fraud case. The defendants raised ten issues on appeal, including challenges to the sufficiency of the evidence, the admission of certain evidence, and the jury selection process.The United States District Court for the Eastern District of Louisiana convicted the defendants on multiple counts, including conspiracy to commit murder-for-hire, murder-for-hire, conspiracy to tamper with a federal witness, and witness tampering. The district court sentenced each defendant to at least one term of life imprisonment. The defendants appealed their convictions and sentences, arguing that the evidence was insufficient to support their convictions and that the district court made several errors in admitting evidence and instructing the jury.The United States Court of Appeals for the Fifth Circuit reviewed the case and found no error in the district court's rulings. The court held that the evidence presented at trial was sufficient to support the defendants' convictions. The court also found that the district court did not abuse its discretion in admitting evidence related to the defendants' prior criminal activities and in denying the defendants' motions to sever their trials. Additionally, the court held that the district court did not err in its jury instructions or in its handling of the jury selection process.The Fifth Circuit affirmed the district court's judgment, upholding the defendants' convictions and sentences. The court concluded that the defendants' arguments on appeal were unpersuasive and that the district court had acted within its discretion in its rulings. View "United States v. Age" on Justia Law

Mark Eugene Ricks, a Texas state prisoner, filed a pro se lawsuit under 42 U.S.C. § 1983 against employees of the University of Texas Medical Branch (UTMB), alleging violations of his Eighth Amendment rights. Ricks claimed that he was denied treatment for chronic hepatitis C virus (HCV) based on nonmedical reasons and that the TDCJ HCV Policy was the driving force behind this unconstitutional denial of treatment. He sought injunctive and declaratory relief, as well as damages.The United States District Court for the Southern District of Texas granted the defendants' motion to dismiss Ricks's complaint for failure to state a claim, concluding that his allegations did not support a claim for deliberate indifference. The district court also denied Ricks's motion for appointment of counsel. Ricks filed a timely appeal, and the district court denied him leave to proceed in forma pauperis (IFP) on appeal, certifying that any appeal would not be taken in good faith.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and found that the district court erred in dismissing Ricks's complaint without allowing him an opportunity to amend his pleadings. The appellate court held that Ricks's allegations, when liberally construed, could potentially raise a viable claim of deliberate indifference. The court also found that the district court abused its discretion in denying Ricks's motion for appointment of counsel without considering the relevant factors set out in Ulmer v. Chancellor.The Fifth Circuit vacated the district court's orders granting the motion to dismiss and denying the appointment of counsel. The case was remanded with instructions for the district court to allow Ricks to amend his pleadings and to appoint counsel to represent him. View "Ricks v. Khan" on Justia Law