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

An airline employee, who began working in 1996 and served as a union representative, was terminated in 2023 after allegedly violating both company policy and the terms of a Last Chance Agreement (LCA) he had previously entered into. The LCA was signed following an earlier incident in which he admitted to theft, and it stipulated that any further violation of company policy during its term would result in immediate termination. In October 2023, the employee entered a restricted area in violation of company policy, leading to his discharge.Following his termination, the employee filed a lawsuit in the United States District Court for the Northern District of Texas, alleging retaliatory termination under the Railway Labor Act (RLA) and asserting that his termination was motivated by anti-union animus due to his activities as a union representative. The airline moved to dismiss the complaint, arguing that the dispute was a “minor” one under the RLA, which meant it was subject to mandatory arbitration as outlined in the collective bargaining agreement (CBA), thus depriving the federal court of subject-matter jurisdiction. The district court agreed and granted the airline’s motion to dismiss under Rule 12(b)(1), finding that the dispute was minor and did not fall within any exceptions allowing for judicial intervention.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court properly dismissed the case for lack of subject-matter jurisdiction. The Fifth Circuit affirmed the district court’s decision, holding that the dispute was a minor one under the RLA because it could be resolved by interpreting the LCA and CBA, and that none of the exceptions to exclusive arbitral jurisdiction applied. The court also found no sufficient evidence of anti-union animus to invoke an exception to arbitral exclusivity. View "Reardon v. American Airlines" on Justia Law

Police officers responded to a call about a man, later identified as Xavier Leonard, who was found injured, disoriented, and partially clothed on the ground in a residential neighborhood. Leonard was unresponsive to questions and exhibited signs of being under the influence of drugs. After determining that Leonard lived nearby, officers noticed an open side door at his house and observed signs inside, such as a broken coffee table, that suggested possible violence or distress. The officers announced their presence and, receiving no response, entered the home to check for potential victims or suspects. While inside, they observed drugs and firearms, left after a brief search, and then obtained a search warrant based on their observations.Leonard was charged in the United States District Court for the Eastern District of Texas with firearm and drug offenses. He requested a motion to suppress the evidence obtained from his home. After his initial attorney declined to file the motion, deeming it frivolous, Leonard was appointed new counsel who proceeded with the suppression motion. The magistrate judge recommended granting the motion, finding that the evidence should be excluded. The district court adopted this recommendation and suppressed the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case after the government appealed. The government did not challenge the Fourth Amendment issue but argued that the exclusionary rule did not apply due to the good faith exception. The Fifth Circuit held that under its “close enough” doctrine, the officers’ actions were objectively reasonable given the circumstances, and the good faith exception precluded exclusion of the evidence. The court reversed the district court’s decision and remanded the case for further proceedings. View "United States v. Leonard" on Justia Law

A former employee of a bank holding company, who participated in a company-sponsored retirement savings plan, brought suit alleging that the bank, the plan’s administrative committee, and a subsidiary breached their fiduciary duties under ERISA, resulting in financial loss to his plan distribution. After the employee’s separation and payout, the company amended the plan in early 2024 to add a retroactive arbitration clause that required all claims to proceed individually in arbitration, barred class or representative actions, and included a jury trial waiver and a provision that only individual relief could be awarded.The United States District Court for the Western District of Texas denied the defendants’ motion to compel arbitration, holding that the arbitration agreement was not valid under Texas law due to lack of consideration. The company appealed, arguing that the plan’s consent, not the individual participant’s, was sufficient to bind parties to arbitration for claims brought on behalf of the plan under 29 U.S.C. § 1132(a)(2), and that the arbitration clause was enforceable. The company also preemptively addressed potential objections under the effective vindication doctrine and claims that the arbitration provisions unlawfully limited statutory remedies.The United States Court of Appeals for the Fifth Circuit reversed the denial of arbitration as to the § 1132(a)(2) claim, holding that the plan’s consent through its unilateral amendment provision was sufficient to bind the participant to arbitration for plan-based claims, but affirmed the denial as to the participant’s individual claims because he had not consented. The court further held that the arbitration clause’s prohibition on representative actions and its limitation to individual relief violated the effective vindication doctrine, and voided the standard-of-review provision to the extent it applied to fiduciary-breach claims. The case was remanded for the district court to determine whether the offending arbitration provisions could be severed. View "Parrott v. International Bank" on Justia Law

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

Fieldwood Energy operated an offshore platform near Louisiana and contracted with United Fire and Safety to provide fire watch services for repairs. Fieldwood also separately chartered a liftboat from Aries Marine to support the work, which included housing and crane services for the contractors. During the project, the liftboat listed and capsized, leading to personal injuries for a United Fire employee. Aries Marine, facing liability claims, sought indemnification from United Fire based on a cross-indemnification clause in the 2013 Master Services Contract (MSC) between Fieldwood and United Fire.The United States District Court for the Eastern District of Louisiana considered cross-motions for summary judgment on whether the MSC was a maritime contract. The district court found that the contract was not maritime in nature, applying Louisiana law via the Outer Continental Shelf Lands Act (OCSLA), which incorporates the law of the adjacent state unless federal maritime law applies. Louisiana’s Oilfield Anti-Indemnity Act invalidated the indemnity provisions. Aries’s motions for reconsideration were denied, leading to this appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court agreed that the MSC did not require or contemplate that a vessel would play a substantial role in the contracted fire watch services. It found that only Fieldwood, not United Fire, expected the liftboat’s substantial involvement, and that such a shared expectation was necessary under circuit precedent to create a maritime contract. Because the parties did not share this expectation, the contract was not maritime, and Louisiana law voided the indemnity provisions. The Fifth Circuit affirmed the district court’s judgment. View "Aries Marine v. United Fire & Safety" on Justia Law

Several pharmaceutical manufacturers and a trade association challenged a Louisiana statute, Act 358, which restricts drug manufacturers from interfering with the delivery of federally discounted drugs through contract pharmacies. The statute was passed in response to manufacturers’ efforts to limit the distribution of discounted drugs under the federal 340B Program, particularly through arrangements with contract pharmacies serving vulnerable populations. The plaintiffs argued that the Louisiana law was preempted by federal law and violated several constitutional provisions, including the Takings Clause, the Contracts Clause, and the Due Process Clause’s prohibition on vagueness.The United States District Court for the Western District of Louisiana considered three related cases together. It denied the manufacturers’ motions for summary judgment and instead granted summary judgment for the State of Louisiana and the Louisiana Primary Care Association (LPCA) on all claims. The district court also allowed LPCA to intervene in each case, over the objection of one plaintiff.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that Act 358 is not preempted by federal law. It found that the federal 340B statute does not occupy the field of pharmacy regulation and does not conflict with or frustrate federal objectives, as it is silent on the use of contract pharmacies and leaves room for state regulation. The court also concluded that Act 358 does not effect a physical or regulatory taking, does not substantially impair contract rights under the Contracts Clause, and is not unconstitutionally vague. However, the Fifth Circuit reversed the district court’s order permitting LPCA to intervene in AbbVie’s case, finding that LPCA’s interests were adequately represented by the State and it did not show it would present a distinct defense. The court affirmed summary judgment for Louisiana on all claims. View "AstraZeneca v. Murrill" on Justia Law

The plaintiff worked as an Agency Manager for a group of insurance companies collectively known as Texas Farm Bureau. In this role, he supervised a team of insurance agents and was classified as an independent contractor. He determined his own work schedule, was not required to report his hours, and was paid through commissions rather than a salary or hourly wage. From 2016 to 2018, his earnings ranged from $552,000 to $627,000 per year. The plaintiff filed suit, claiming he was misclassified and seeking unpaid overtime under the Fair Labor Standards Act, arguing he should have been treated as an employee.The United States District Court for the Western District of Texas ruled at summary judgment that the plaintiff should have been classified as an employee and was owed at least 816 hours of overtime. The only issue left for trial was whether the employer knew or should have known about the plaintiff’s overtime work. A jury found that the employer neither had actual nor constructive knowledge of any overtime. The plaintiff’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of these motions. The appellate court held that an employee seeking overtime pay must prove the employer had actual or constructive knowledge of the overtime work. The court found that allowing an employee to set his own hours does not, by itself, establish employer knowledge of overtime. The lack of a timekeeping system did not constitute constructive knowledge, nor did it shift the burden of proof to the employer. The appellate court also held that the district court’s jury instruction, which required the employee to notify the employer of overtime, was proper. The Fifth Circuit affirmed the district court’s rulings. View "Merritt v. Texas Farm Bureau" on Justia Law

A Texas nonprofit health center, CentroMed, experienced a data breach in 2024 that exposed the personal information of its patients. Arturo Gonzalez, representing himself and others affected, filed a class action in Bexar County, Texas, alleging that CentroMed failed to adequately protect their private information. CentroMed, which receives federal funding and has occasionally been deemed a Public Health Service (PHS) employee under federal law, sought to remove the case to federal court, claiming removal was proper under 42 U.S.C. § 233 and 28 U.S.C. § 1442.After CentroMed was served, it notified the Department of Health and Human Services (HHS) and the United States Attorney, seeking confirmation that the data breach claims fell within the scope of PHS employee immunity. The United States Attorney appeared in state court within the required 15 days, ultimately informing the court that CentroMed was not deemed a PHS employee for the acts at issue because the claims did not arise from medical or related functions. Despite this, CentroMed removed the case to the United States District Court for the Western District of Texas 37 days after service. The district court granted Gonzalez’s motion to remand, concluding that removal was improper under both statutes: the Attorney General had timely appeared, precluding removal under § 233, and removal under § 1442 was untimely.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s remand. The Fifth Circuit held that CentroMed could not remove under § 233 because the Attorney General had timely appeared and made a case-specific negative determination. The court further held that removal under § 1442 was untimely, as CentroMed did not remove within 30 days of receiving the initial pleading. Thus, the remand to state court was affirmed. View "Gonzalez v. El Centro Del Barrio" on Justia Law

Two Mexican nationals entered the United States illegally, one in 2009 and the other in 2001. In 2025, both were apprehended by Department of Homeland Security (DHS) officials, who determined that they were inadmissible because they were present in the United States without having been lawfully admitted or paroled. Consequently, DHS initiated removal proceedings against both individuals and detained them under 8 U.S.C. § 1225(b)(2)(A) without bond pending the outcome of those proceedings.Each petitioner requested a bond hearing before an immigration judge, but both requests were denied on the grounds that § 1225(b)(2)(A) mandated detention without bond for “applicants for admission” who are not “clearly and beyond a doubt entitled to be admitted.” Subsequently, both individuals filed habeas corpus petitions in the United States District Court for the Southern District of Texas, arguing that they were entitled to bond hearings under 8 U.S.C. § 1226(a). The district courts agreed, concluding that because the petitioners were not actively “seeking admission” at the time of apprehension, their detention was governed by § 1226(a), which allows for discretionary bond. Both petitioners received bond hearings and were released.The United States Court of Appeals for the Fifth Circuit reviewed the consolidated government appeals. The Fifth Circuit reversed the district courts’ orders. The court held that individuals present in the United States without having been admitted—regardless of how long they have resided here—are deemed “applicants for admission” under § 1225(a)(1) and are therefore subject to mandatory detention under § 1225(b)(2)(A) without eligibility for bond during removal proceedings. The court found that the statutory text, structure, and context supported the government’s interpretation, and the prior practice of allowing bond did not override the statute’s plain meaning. The cases were remanded for further proceedings consistent with this holding. View "Buenrostro-Mendez v. Bondi" on Justia Law

Marquis Kennedy sought employment as a police officer with the City of Arlington, Texas, and enrolled in the Arlington Police Academy after passing a physical exam. During a mandatory training exercise known as Gracie Survival Tactics, which involved intense self-defense scenarios, Marquis reportedly complained of fatigue, thirst, and lightheadedness, but was not permitted breaks or water. He continued participating, allegedly due to fear of failing and repeating the training. During the final scenario, Marquis signaled distress, but the instructors continued the exercise until he could not proceed. After the simulation ended, Marquis requested an ambulance, was assisted to a break room, and subsequently suffered cardiac arrest. Emergency services were called, and Marquis was taken to a hospital, where he died two days later. The autopsy listed cardiac arrest as the cause of death, likely due to atherosclerotic cardiovascular disease.Kennedy, Marquis’s widow, brought suit in the United States District Court for the Northern District of Texas against the City and several officers, asserting Fourth and Fourteenth Amendment violations under 42 U.S.C. § 1983, including claims for excessive force, deliberate indifference to medical needs, bystander liability, and municipal liability for failure to train officers. The City moved to dismiss and submitted video evidence of the training, which Kennedy referenced in her claims. The magistrate judge recommended dismissal of all claims, finding no plausible constitutional violation, no constitutional seizure, and no duty of medical care in an employment setting. The district court adopted these findings and dismissed the case.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Kennedy failed to plausibly allege a Fourth Amendment seizure or substantive due process violation, and that no constitutional duty of medical care existed in this employment context. The court also found no basis for bystander or municipal liability. View "Kennedy v. City of Arlington, Texas" on Justia Law