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

During the COVID-19 pandemic, Congress established the Paycheck Protection Program (PPP) to help eligible small businesses maintain payroll through government-mandated shutdowns. The program, administered by the Small Business Administration (SBA), provided for government-guaranteed loans to qualifying businesses, with the possibility of loan forgiveness if certain conditions were met. Bruckner Truck Sales received a $10 million PPP loan, but the SBA later determined that Bruckner was not eligible for the loan. Despite conceding its ineligibility, Bruckner refused to return the funds and instead claimed entitlement to loan forgiveness under the CARES Act.The United States District Court for the Northern District of Texas reviewed the case after Bruckner challenged the SBA’s denial of forgiveness. The district court granted summary judgment in favor of the government, holding that the CARES Act does not entitle ineligible borrowers to loan forgiveness. The court also denied Bruckner’s motion to alter or amend the judgment, finding that the SBA’s interpretation of the statute was correct and that the agency’s actions were not arbitrary or capricious.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decision. The Fifth Circuit held that the CARES Act limits loan forgiveness to borrowers who were eligible for the underlying PPP loan. The court rejected Bruckner’s arguments that the SBA’s rule was retroactive, that the agency violated the Chenery doctrine, and that the district court improperly deferred to the agency’s interpretation. The court concluded that neither the text nor the structure of the CARES Act supports forgiveness for ineligible borrowers, and affirmed the denial of loan forgiveness and the requirement to return the funds. View "Bruckner Truck Sales v. Guzman" on Justia Law

A woman brought suit against the United States under the Federal Tort Claims Act (FTCA) after her child suffered severe and permanent nerve damage during childbirth at a Texas hospital. She alleged that the resident physician who delivered her baby used excessive force in responding to a complication known as shoulder dystocia, and that the attending physician failed to properly supervise. The plaintiff sought compensatory damages for medical care and related expenses.The United States District Court for the Western District of Texas dismissed the case for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). The district court, adopting a magistrate judge’s recommendation, determined that shoulder dystocia is always an obstetrical emergency under Texas law. It concluded that, in such emergencies, Texas law requires proof of “willful and wanton negligence” (a heightened standard akin to gross negligence). The court further reasoned that because the FTCA does not waive sovereign immunity for punitive damages, and because damages for willful and wanton negligence are punitive, it lacked jurisdiction to hear the case.On appeal, the United States Court of Appeals for the Fifth Circuit reversed and remanded. The Fifth Circuit held that the district court erred in two respects: first, by presuming as a matter of law that the physician provided emergency medical care in every instance of shoulder dystocia, rather than treating it as a factual question; and second, by conflating the heightened standard of liability (willful and wanton negligence) with the nature of damages recoverable. The Fifth Circuit clarified that compensatory damages for gross negligence are available under Texas law and are not barred by the FTCA, which only precludes punitive damages. The case was remanded for further proceedings. View "Robledo v. USA" on Justia Law

Donald Wright was employed by Honeywell International for fourteen years as a Dock B Operator. In 2021, Honeywell instituted a mandatory COVID-19 vaccination policy in response to a federal executive order affecting federal contractors. Wright, a Baptist Christian, requested a religious exemption from the policy, citing his belief in God-given bodily autonomy and referencing certain scriptural passages. He also submitted a third-party attestation from his daughter, who explained their shared religious beliefs. Honeywell denied his exemption request, stating that Wright had not adequately identified a sincerely held religious belief prohibiting vaccination. Wright was subsequently suspended and then terminated for failing to comply with the vaccination requirement.Wright filed a charge of discrimination with the Equal Employment Opportunity Commission and, after receiving a right-to-sue letter, brought suit in the United States District Court for the Middle District of Louisiana. He alleged religious discrimination and disparate treatment under Title VII. The district court granted summary judgment in favor of Honeywell on all claims, finding that Wright had not provided sufficient evidence to raise a genuine issue of material fact regarding the existence of a bona fide religious belief or that he had informed Honeywell of such a belief. Wright’s motion for reconsideration was denied, and he appealed, but only as to the religious discrimination claim.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment decision de novo. The Fifth Circuit held that Wright had presented sufficient evidence to create a genuine dispute of material fact as to whether he held a bona fide religious belief and whether he informed Honeywell of that belief. The court reversed the district court’s grant of summary judgment on the Title VII religious discrimination claim and remanded the case for further proceedings. The court did not address the disparate treatment claim or the motion for reconsideration, as those issues were either not appealed or rendered moot. View "Wright v. Honeywell International" on Justia Law

Texas enacted a law in 2021 requiring voters who wish to vote by mail to provide an identification number—such as a driver’s license or the last four digits of their Social Security number—on both their mail-in ballot applications and the ballots themselves. This number must match the one provided during voter registration. If the numbers do not match or are missing, the application or ballot is rejected. The law was challenged by the United States and several private plaintiffs, who argued that these requirements violate the materiality provision of the Civil Rights Act of 1964, which prohibits denying the right to vote due to errors or omissions on paperwork if those errors are not material to determining voter qualification.The United States District Court for the Western District of Texas consolidated the lawsuits and denied Texas’s motion to dismiss, finding that the plaintiffs had standing and that sovereign immunity did not bar the private plaintiffs’ claims. After discovery, the district court granted summary judgment for the plaintiffs, holding that the identification number requirement was not material to voter eligibility and enjoined Texas from enforcing the number-matching provisions.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the district court lacked jurisdiction over the private plaintiffs’ claims against the Secretary of State due to a pending appeal on sovereign immunity, but found no jurisdictional bar to reviewing the United States’ claims. The Fifth Circuit held that the identification number requirement is material to determining whether an individual is qualified to vote under Texas law, as it serves to confirm the voter’s identity and prevent fraud. The court concluded that the law complies with the materiality provision of the Civil Rights Act and reversed the district court’s judgment, rendering judgment for the defendants. View "USA v. Paxton" on Justia Law

Three registered Texas voters alleged that three local officials—a justice of the peace, a sheriff, and a constable—conspired to punish them for political reasons. The plaintiffs were arrested after reporting for jury duty, accused of falsely claiming residency in Loving County. The officials argued they were enforcing voter-eligibility rules, while the plaintiffs claimed it was retaliation to silence dissent. The plaintiffs sued under § 1983, alleging constitutional violations.The United States District Court for the Western District of Texas granted judicial and quasi-judicial immunity to the officials for some claims but denied judicial immunity for actions related to the jury proceeding. The officials appealed the denial of judicial immunity, and the plaintiffs cross-appealed the grant of immunity on other claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that presiding over the jury proceeding was a judicial act protected by absolute judicial immunity. Consequently, the court reversed the district court's denial of judicial immunity for the jury proceeding. Regarding the plaintiffs' cross-appeal, the court found it lacked jurisdiction to review those claims at this interlocutory stage and dismissed the cross-appeal.The court's main holding was that the actions of the justice of the peace in presiding over the jury proceeding were judicial in nature and thus protected by absolute judicial immunity. The court reversed the district court's decision in part and dismissed the cross-appeal for lack of jurisdiction. View "Jones v. King" on Justia Law

The Institute for Free Speech (IFS), a nonprofit organization that provides pro bono legal services for First Amendment litigation, sought to represent a Texas politician and a political committee in challenging a Texas election law. This law requires political advertising signs to include a government-prescribed notice. IFS refrained from entering into representation agreements due to fear of prosecution under the Texas Election Code, which prohibits corporations from making political contributions, including in-kind contributions such as pro bono legal services.The United States District Court for the Western District of Texas dismissed IFS's complaint for lack of Article III standing, concluding that IFS's claims were not ripe and that qualified immunity barred the individual-capacity claims. The district court assumed IFS had standing but found that the claims were not ripe because the prospective clients did not yet qualify as a candidate and a political committee. The court also concluded that sovereign immunity did not bar the official-capacity claims.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that IFS had standing to pursue its claims. The court found that IFS had demonstrated a serious intent to engage in constitutionally protected conduct, that its proposed conduct would violate Texas law, and that there was a substantial threat of enforcement. The court also concluded that IFS's claims were ripe for adjudication, as the prospective clients qualified as a candidate and a political committee under Texas law.The Fifth Circuit held that the district court erred in dismissing the case for lack of standing and ripeness. However, the court affirmed the dismissal of the individual-capacity claims based on qualified immunity, as the right to provide pro bono legal services in this context was not clearly established. The court also affirmed that the Ex parte Young exception to sovereign immunity applied, allowing the official-capacity claims to proceed. The case was remanded for further proceedings consistent with the opinion. View "Institute for Free Speech v. Johnson" on Justia Law

Mary Bennett owns a farm on the U.S.–Mexico border. In 2008, the United States built a segment of the border wall on a portion of her property where it had an easement. In 2020, the government initiated a condemnation action to take that portion of the land and surrounding areas to further build the wall and make related improvements. Bennett argued that the government exceeded the scope of its easement when it built the wall, claiming ownership of the wall and seeking just compensation for its value. She attempted to present expert testimony on the wall's value, which the district court excluded.The United States District Court for the Southern District of Texas excluded Bennett's expert testimony, concluding that she was not entitled to just compensation for the wall's value. The court interpreted the common-law rule from Searl v. School-Dist. No. 2, which states that fixtures built by a trespasser become part of the estate, to include an exception for trespassers with an objective, good-faith belief in their right to build. The court found that the government had such a belief and thus precluded Bennett from recovering the wall's value. Bennett appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the government acted under its power of eminent domain, which cannot be limited by state trespass laws. The court affirmed that Bennett is entitled to compensation for the land taken but not for the value of the wall, as the government built it at its own expense for a public purpose. The court affirmed the district court's exclusion of the expert testimony and remanded the case for further proceedings consistent with this opinion. View "United States v. Bennett" on Justia Law

Ismael Adan Ortiz-Rodriguez, a non-citizen, was removed from the United States in 2017 following expedited removal proceedings initiated by DHS. In 2023, he was convicted of illegal reentry under 8 U.S.C. § 1326(a). Before trial, Ortiz-Rodriguez moved to dismiss his indictment by collaterally attacking his 2017 deportation order under 8 U.S.C. § 1326(d), arguing that his expedited removal involved an unknowing and involuntary waiver of judicial review and violated his due process rights. The district court denied his motion.The United States District Court for the Western District of Texas found Ortiz-Rodriguez guilty and sentenced him to fifty-one months of imprisonment. He appealed the decision, arguing that his 2017 expedited removal proceedings were fundamentally unfair and deprived him of judicial review. The district court also revoked his supervised release from a prior § 1326 prosecution, sentencing him to an additional fourteen months of imprisonment.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s judgment. The court held that Ortiz-Rodriguez did not satisfy the requirements of 8 U.S.C. § 1326(d) because he failed to show that the 2017 expedited removal proceedings deprived him of the opportunity for judicial review or that the entry of the order was fundamentally unfair. The court noted that Ortiz-Rodriguez had the right to appeal his expedited removal but did not do so, and his waiver of the right to appeal was considered and intelligent. Additionally, the court found that changes in substantive law after his removal did not render the proceedings fundamentally unfair or procedurally deficient. View "United States v. Ortiz-Rodriguez" on Justia Law

The Vinales family leased a home at Randolph Air Force Base, managed by AETC II Privatized Housing, LLC, and other associated entities. They experienced issues with the home's condition, including mold and asbestos, which they claimed led to health problems and property damage. They sued the housing providers for breach of contract, fraud, and other claims, seeking damages and attorneys' fees.The United States District Court for the Western District of Texas granted summary judgment for the defendants on most claims, citing the federal enclave doctrine, which limits applicable law to federal law and pre-cession state law. The court dismissed the fraud claim for lack of evidence and denied the plaintiffs' motion for attorneys' fees. The breach of contract claim proceeded to trial, where the jury awarded the plaintiffs over $90,000 in damages. The magistrate judge denied the plaintiffs' motion for attorneys' fees and the defendants' motion for judgment as a matter of law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the application of the federal enclave doctrine, which barred most of the plaintiffs' claims. It upheld the dismissal of the fraud claim, agreeing that the plaintiffs failed to identify actionable fraudulent statements. The court also affirmed the denial of attorneys' fees, finding no legal basis for the award. The exclusion of certain evidence at trial was deemed not to be an abuse of discretion. The court found sufficient evidence to support the jury's damages awards for personal property and diminution in rental value. Finally, the court held that the jury instructions were proper and did not create substantial doubt about the jury's guidance. The judgment of the magistrate judge was affirmed. View "Vinales v. AETC II Privatized Housing, LLC" on Justia Law

In 2017, Darrell Wickware was convicted of robbery under Texas law and sentenced to three years in prison. In May 2021, he was found with a 9-millimeter pistol and charged with unlawful possession of a firearm by a convicted felon. In January 2022, he was indicted for violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) and pleaded guilty. At his sentencing hearing in June 2024, Wickware argued that his prior robbery conviction did not qualify as a "crime of violence" under the amended Sentencing Guidelines. The district court, bound by Fifth Circuit precedent, sentenced him to 24 months in prison. Wickware appealed.The United States District Court for the Northern District of Texas ruled that Wickware's robbery conviction was a crime of violence under the Sentencing Guidelines. Wickware appealed, arguing that amendments to the Guidelines changed the characterization of his robbery conviction. The district court disagreed, stating it was bound by Fifth Circuit precedent, and sentenced Wickware to 24 months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Wickware contended that the district court erred in finding his argument foreclosed by circuit precedent. The Fifth Circuit examined the elements of Texas robbery and the amended Guidelines' definition of robbery. The court found that the elements of Texas robbery were the same or narrower than those of the Guidelines' generic robbery offense. Consequently, the court held that Wickware's Texas robbery conviction constituted a "crime of violence" under U.S.S.G. § 4B1.2(a)(2). The Fifth Circuit affirmed the district court's decision. View "United States v. Wickware" on Justia Law