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

L. N., a native of Angola, sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the United States. She claimed persecution due to her and her father's opposition to corruption in Angola, citing incidents including her home being shot at in 2008, an assault in Ecuador in 2016, and her house being set on fire in 2017. L. N. argued that these incidents were connected to her father's anti-corruption activities.The Immigration Judge (IJ) denied L. N.'s applications, finding she did not establish a well-founded fear of persecution. The Board of Immigration Appeals (BIA) initially remanded the case to the IJ to consider expert testimony and the feasibility of internal relocation within Angola. On remand, the IJ again denied her claims, and the BIA affirmed this decision, leading L. N. to petition for review.The United States Court of Appeals for the Fifth Circuit reviewed the decisions of both the BIA and the IJ. The court applied the substantial evidence standard for factual findings and de novo review for constitutional claims and questions of law. The court found that substantial evidence supported the BIA's conclusion that L. N. did not suffer state-sponsored persecution and that the Angolan government was willing and able to protect her. The court also held that the BIA did not err in its analysis of past and future persecution and that substantial evidence supported the denial of CAT protection. Consequently, the Fifth Circuit denied L. N.'s petition for review. View "L. N. v. Garland" on Justia Law

Christa Taylor purchased an automobile insurance policy from Root Insurance Company. After her vehicle was damaged in a hailstorm, Root determined it to be a total loss and paid Taylor the vehicle's actual cash value of $22,750. However, Root did not include an amount representing the sales tax in this payment. Taylor argued that the policy required Root to pay the applicable sales tax in addition to the actual cash value and filed a putative class action for breach of contract and violation of the Texas Prompt Payment of Claims Act (TPPCA).The United States District Court for the Western District of Texas reviewed the case. Root moved to dismiss Taylor's claims under Federal Rule of Civil Procedure 12(b)(6). The magistrate judge recommended granting Root's motion and denying Taylor's request for leave to amend her complaint. The district court conducted a de novo review, agreed with the magistrate judge, and dismissed the suit. Taylor then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the insurance policy's language required Root to pay only the "applicable sales tax," and since a total-loss settlement is not considered a sale under Texas law, no sales tax was applicable. The court also noted that actual cash value does not include taxes and fees payable to purchase a replacement vehicle under Texas law. Consequently, Root did not breach the policy, nor did it violate the TPPCA. The court affirmed the district court's dismissal of Taylor's claims. View "Taylor v. Root Insurance" on Justia Law

Dr. Joseph Papin, a medical resident at the University of Mississippi Medical Center (UMMC), was terminated following a series of complaints about his workplace behavior, culminating in a serious incident involving patient care. Dr. Papin alleged that his troubles began in December 2016, but UMMC presented evidence of issues from the start of his residency. Dr. Papin entered into a "Remediation Agreement" with Dr. T. Mark Earl, the residency program director, which was supposed to give him sixty days to improve. However, UMMC terminated his employment before the remediation period ended, leading Dr. Papin to sue for breach of contract.The United States District Court for the Southern District of Mississippi held an eight-day trial, where a jury found that UMMC breached the Remediation Agreement, awarding Dr. Papin over $6.5 million in damages, including punitive damages. However, the trial court set aside the jury's verdict, granting UMMC's motion for judgment as a matter of law (JMOL). The court ruled that Dr. Earl did not have the authority to enter into a binding contract on behalf of UMMC, as required by Mississippi law for public institutions.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Remediation Agreement was not a valid contract because Dr. Earl lacked the actual authority to bind UMMC. Mississippi law requires strict adherence to prescribed contracting procedures for public institutions, and only specific officials, such as the Vice Chancellor for Health Affairs or the Associate Dean for Graduate Medical Education, had the authority to enter into employment contracts. The court also found that the ACGME guidelines cited by Dr. Papin did not override Mississippi's legal requirements for public contracts. Thus, the appellate court upheld the JMOL in favor of UMMC. View "Papin v. University of Mississippi Medical Center" on Justia Law

SO Apartments, LLC and Elm Creek, LLC (the “Complexes”) challenged the City of San Antonio’s Proactive Apartment Inspection Program (PAIP), which was created to address property maintenance code violations. The PAIP requires multifamily apartment complexes with five or more units to enroll if they receive three or more code citations over six months that are not cured. Enrolled complexes are subject to monthly inspections and a $100 per-unit, per-year fee. The Complexes received multiple code violation notices, failed to cure them, and were fined and enrolled in the PAIP, resulting in significant fees.The Complexes filed suit in the United States District Court for the Western District of Texas, arguing that the PAIP violated the Fourth Amendment by allowing warrantless inspections, the Eighth Amendment by imposing excessive fines, and the Fourteenth Amendment by denying procedural and substantive due process. The district court denied their request for a preliminary injunction, finding they failed to show a likelihood of success on the merits, irreparable harm, that the balance of harms favored them, or that an injunction would serve the public interest.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that the PAIP does not authorize warrantless searches, as it does not explicitly state that city officials can conduct searches without a warrant. The $100 per-unit fee was found to be administrative rather than punitive, and thus not excessive under the Eighth Amendment. The court also found that the PAIP provided adequate procedural due process through its notice and appeal processes. Lastly, the court determined that the Complexes failed to show that the PAIP’s requirements were so egregious as to violate substantive due process. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "SO Apartments v. City of San Antonio" on Justia Law

Joseph Boswell, Sr. was convicted by a jury of bankruptcy fraud and tax evasion. Boswell operated a business servicing pizza ovens and stopped reporting income and paying taxes around 1995. He filed for bankruptcy in 2011, claiming significant back taxes owed. The government alleged that Boswell used various corporate entities, nominally owned by family members, to conceal assets from the IRS and creditors. During his bankruptcy, Boswell reported minimal assets and income, despite evidence suggesting he controlled significant funds through these entities.The United States District Court for the Western District of Louisiana oversaw the initial trial. Boswell moved to dismiss the bankruptcy fraud charge, arguing it was untimely and that the indictment was improperly sealed. The district court denied this motion, finding the government had a legitimate reason for sealing the indictment. Boswell also requested a bill of particulars, which the court denied, and he was ultimately convicted on both counts. The district court sentenced him to sixty months in prison and ordered restitution to the IRS.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the government failed to demonstrate a legitimate prosecutorial purpose for sealing the indictment, which meant the statute of limitations was not tolled, rendering the bankruptcy fraud charge untimely. Consequently, the court reversed Boswell's conviction on the bankruptcy fraud charge. However, the court affirmed the tax evasion conviction, finding sufficient evidence to support the jury's verdict. The court also upheld the district court's jurisdiction to impose restitution while the appeal was pending and found no cumulative errors warranting a new trial for the tax evasion charge. View "USA v. Boswell" on Justia Law

The plaintiffs, five Muslim U.S. citizens, allege they have been placed on the Terrorist Screening Dataset, commonly known as the "terrorist watchlist." This list includes the No-Fly List, which prevents individuals from boarding flights, and the Selectee List, which subjects individuals to enhanced security screening. Four plaintiffs claim they are on the Selectee List due to repeated enhanced screenings, while one plaintiff, Adis Kovac, claims he is on both the No-Fly List and the Selectee List. Each plaintiff sought redress through the Department of Homeland Security’s Traveler Redress Inquiry Program (TRIP), but only Kovac received confirmation of his No-Fly List status.The plaintiffs filed a lawsuit in the U.S. District Court for the Northern District of Texas against various federal agency heads, alleging violations of their constitutional rights and unlawful agency action under the Administrative Procedure Act (APA). The district court dismissed several claims, including due process and equal protection claims, and later dismissed Kovac’s No-Fly List claims as moot after he was removed from the list. The remaining APA claims were addressed at summary judgment, where the district court ruled that the agencies had statutory authority to maintain the watchlist and that the TRIP procedures were not arbitrary and capricious.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 the relevant federal agencies have clear statutory authority to create, maintain, and use the watchlist for screening airline passengers. The court found that the statutory framework, including the Aviation and Transportation Security Act, the Homeland Security Act, and subsequent legislation, provided unambiguous authority for the watchlist. The court did not address whether the major questions doctrine applied, as the statutory authority was clear. The court also concluded that the plaintiffs lacked standing to challenge the watchlist’s use in contexts unrelated to airport security. View "Kovac v. Wray" on Justia Law

In July 2020, Taylor Hildreth was a passenger in a car stopped by police at known narcotics locations. The driver consented to a search, and Hildreth admitted to having drugs in his pant leg, which led to the discovery of methamphetamine, Xanax, and drug paraphernalia. A loaded firearm was found in the glove compartment, which Hildreth admitted was his, knowing he was barred from possessing it due to a prior felony conviction. Hildreth was indicted for being a felon in possession of a firearm and released on pretrial supervision. He was later arrested for assaulting his father, violating his pretrial conditions, and was ordered to in-patient drug treatment, which he completed after an initial discharge for policy violations.The United States District Court for the Southern District of Texas reviewed the case. Hildreth pleaded guilty to the firearm possession charge. The presentence investigation report (PSR) calculated a total offense level of eighteen and a criminal history category IV, resulting in a Guidelines range of forty-one to fifty-one months. The PSR recommended no adjustment for acceptance of responsibility due to Hildreth's continued criminal conduct. The district court denied the adjustment and imposed an upward departure, sentencing Hildreth to eighty months' imprisonment followed by three years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. Hildreth raised four challenges: the inclusion of a prior misdemeanor in his criminal history, the denial of an acceptance of responsibility adjustment, the upward departure in sentencing, and the constitutionality of 18 U.S.C. § 922(g)(1). The court found no clear or obvious error in including the misdemeanor, upheld the denial of the adjustment based on continued criminal conduct, found no abuse of discretion in the upward departure, and rejected the constitutional challenge based on existing precedent. The Fifth Circuit affirmed Hildreth's sentence and conviction. View "U.S. v. Hildreth" on Justia Law

David Devaney, Jr. was convicted of participating in a drug trafficking conspiracy. He provided security for a drug deal orchestrated by his father, which went wrong when the buyers refused to go to a hotel room. This led to a car chase where David and his co-conspirators shot at the buyers, injuring one and killing a bystander. David was later identified by one of the buyers and arrested after a high-speed chase. In his post-arrest interview, he admitted to his role in the drug deal but denied firing a gun. Searches of his car and cell phones revealed drugs and incriminating messages.The United States District Court for the Northern District of Texas denied David’s motions to suppress evidence from his car and cell phones, as well as his post-arrest statements. The court found him guilty of conspiracy to possess methamphetamine with intent to distribute and sentenced him to 480 months in prison. David appealed, challenging the suppression rulings and the calculation of his offense level under the Sentencing Guidelines.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court upheld the district court’s denial of the suppression motions, finding that the search warrants were supported by probable cause and that David did not unequivocally invoke his right to counsel during his post-arrest interview. The court also affirmed the district court’s application of the Sentencing Guidelines, including the cross-reference to the murder guideline, which set David’s offense level at 43. The court concluded that any other potential errors in the sentencing calculation were harmless, as the cross-reference dictated the offense level. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Devaney" on Justia Law

A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law

Marek Matthews, a seaman and captain, filed a lawsuit against Tidewater, Inc. and Tidewater Crewing, Ltd., alleging that he was exposed to toxic chemicals during his employment, resulting in severe health issues including end-stage renal failure and stage IV cancer. Matthews, a Florida resident, claimed that the exposure occurred while working on offshore supply vessels in the Red Sea. His employment contract included a forum-selection clause mandating that any disputes be litigated in the High Court of Justice in London, England.Initially, Matthews and other plaintiffs filed the suit in Louisiana state court, asserting claims under the Jones Act and general maritime law. Tidewater removed the case to the United States District Court for the Eastern District of Louisiana and moved to dismiss it based on the forum-selection clause and, alternatively, for failure to state a claim. The district court granted the motion to dismiss on forum non conveniens grounds, finding the forum-selection clause valid and enforceable. Matthews's subsequent motion to reconsider the dismissal was denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision, holding that the forum-selection clause was enforceable. The court applied a de novo review to the enforceability of the clause and an abuse of discretion standard to the forum non conveniens analysis. It concluded that Matthews did not meet the heavy burden of proving the clause was unreasonable under the circumstances, despite his health conditions and Louisiana's public policy against such clauses. The court emphasized the federal policy favoring the enforcement of forum-selection clauses in maritime contracts, which outweighed the conflicting state policy. View "Matthews v. Tidewater" on Justia Law