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

The case involves Michael Garrett, a prisoner in the Texas Department of Criminal Justice system for over thirty years, who contends that the prison's schedule allows him only three and a half hours of sleep per night, with a maximum of two and a half hours of continuous sleep. According to Garrett, this sleep deprivation constitutes a violation of the Eighth Amendment's ban on cruel and unusual punishment. He sued the Department after his complaints were ignored by prison officials.The United States District Court for the Southern District of Texas dismissed Garrett's claim, reasoning that he failed to demonstrate a direct causal relationship between his health issues and his sleep deprivation. The court also held that the prison officials' actions did not constitute deliberate indifference, as the schedule was based on legitimate penological purposes.Upon appeal, the United States Court of Appeals for the Fifth Circuit found that the district court had applied incorrect legal standards. The appellate court held that to establish a violation of the Eighth Amendment, a prisoner need only show a substantial risk of serious harm, not actual harm. Furthermore, the court clarified that the prison’s penological purpose has no bearing on whether an inmate has shown “deliberate indifference” for purposes of an Eighth Amendment claim. The case was vacated and remanded to the district court to apply the correct legal standards. View "Garrett v. Lumpkin" on Justia Law

The case involves a petition by Inhance Technologies, L.L.C. against orders issued by the United States Environmental Protection Agency (EPA). Inhance, a company that has been fluorinating plastic containers since 1983, was charged by the EPA for violating a Significant New Use Rule regarding long-chain perfluoroalkyls (PFAS) due to the presence of PFAS in an insecticide stored in a container fluorinated by Inhance. PFAS are long-lasting chemicals found in various products and have been linked to several health issues. The EPA issued two orders under Section 5 of the Toxic Substances Control Act (TSCA), prohibiting Inhance from manufacturing or processing PFAS during its fluorination process. Inhance claimed that if the orders were enforced, they would shutdown their fluorination process and bankrupt the company.The United States Court of Appeals for the Fifth Circuit ruled in favor of Inhance, stating that the EPA exceeded its statutory authority by issuing the orders. The court held that Inhance's decades-old fluorination process could not be deemed a "significant new use" under Section 5 of TSCA. The court vacated the EPA's orders and noted that the EPA could regulate Inhance's fluorination process under Section 6 of TSCA, which requires a cost-benefit analysis for ongoing uses. The court's ruling was based on the interpretation of the term "new" in TSCA, the statutory framework, and the requirement for agencies to provide fair notice of their rules. View "Inhance Technologies v. EPA" on Justia Law

In a case before the United States Court of Appeals for the Fifth Circuit, the defendant, Clarence Santiago, appealed both his conviction and sentence related to drug trafficking and firearms charges. Santiago and his co-conspirators were selling marijuana from a hotel room when they were robbed at gunpoint by previous buyers, leading to a shootout. Santiago was apprehended and confessed to his involvement in the crime.Santiago pleaded guilty to four separate charges but later moved to withdraw his plea, arguing that the presentence investigation report recommended he be improperly punished for attempted first-degree murder. The district court sentenced Santiago to 360 months, a decision he appealed on multiple grounds.The Court of Appeals found no reversible error in Santiago's plea but held that the district court erred in calculating the guideline range for sentencing. The court noted that Santiago and his co-conspirators were under threat during the shootout, which may have been an act of self-defense rather than attempted murder.Given this, the Court of Appeals found that the district court committed clear error by applying an attempted-murder cross-reference without considering Santiago's potential self-defense. The court affirmed Santiago's conviction but vacated the sentence and remanded the case for resentencing. View "USA v. Santiago" on Justia Law

In a case heard by the United States Court of Appeals for the Fifth Circuit, R.J. Reynolds Tobacco Company and other cigarette manufacturers and retailers challenged the Food and Drug Administration's (FDA) new warning-label requirement for cigarette packages and advertisements, citing violations of the First Amendment, the Administrative Procedure Act (APA), and the requirements of the Family Smoking Prevention and Tobacco Control Act (TCA). The district court ruled in favor of the plaintiffs based on their First Amendment claim, without addressing the remaining claims.The FDA appealed, and the appellate court reversed the district court's decision. The court held that the warnings were both factual and uncontroversial, thus qualifying for scrutiny under the standard set by the Supreme Court in Zauderer v. Office of Disciplinary Council of Supreme Court of Ohio. In that case, the Supreme Court held that the government could constitutionally require advertisers to disclose purely factual and uncontroversial information, provided the requirements are reasonably related to a substantial government interest and not unjustified or unduly burdensome.Applying the Zauderer standard, the court determined that the FDA's warnings were justified by the government's interest in promoting greater public understanding of the negative health consequences of smoking and were not unduly burdensome. As such, the court concluded that the warnings did not violate the First Amendment. The court remanded the case back to the district court for consideration of the remaining claims under the APA. View "R J Reynolds Tobacco v. FDA" on Justia Law

In this case, the United States Court of Appeals for the Fifth Circuit reversed a verdict from the United States District Court for the Northern District of Texas. The plaintiffs, C. Sidney Johnston and Danette Johnston, had sued Ferrellgas, Incorporated after Mr. Johnston was injured using a propane tank manufactured by Ferrellgas. A jury had found Ferrellgas liable for a manufacturing defect and negligence and awarded the Johnstons $7 million, which the district court reduced to $1.7 million. On appeal, Ferrellgas contended that the district court erred in denying its motion for judgment as a matter of law because there was insufficient evidence to support the verdict.The Court of Appeals agreed with Ferrellgas. The Court found that there was no substantial evidence to support the jury's finding that the tank was defective when it left Ferrellgas's possession, a crucial element of a manufacturing defect claim. The Court also found that the negligence claim must fail, as it was dependent on the tank having a manufacturing defect.The Court therefore reversed the district court's denial of Ferrellgas's motion for judgment as a matter of law on both the manufacturing defect and negligence claims, and rendered judgment for Ferrellgas. View "Johnston v. Ferrellgas" on Justia Law

The United States Court of Appeals for the Fifth Circuit affirmed the conviction and sentence of defendant Vincent Marchetti, Jr., who was found guilty of one count of conspiracy to commit illegal remunerations in violation of 18 U.S.C. § 371. Marchetti was involved in a scheme wherein Vantari Genetics LLC, a medical laboratory, paid distributors to attract Medicare referrals to Vantari. Marchetti, who operated Advanced Life Sciences LLC, was one of the distributors and had a network of sub-distributors. The court found sufficient evidence that Marchetti was knowingly and actively participating in a scheme involving CodonDx, another entity, that violated the Anti-Kickback Statute. The court rejected Marchetti's challenges regarding the sufficiency of the evidence, the district court's failure to submit his theory of defense instruction, the court's alleged constructive amendment of the indictment, and the court's application of the sentencing guidelines. The court also dismissed his claim for a new trial based on cumulative error. View "USA v. Marchetti" on Justia Law

This federal appeal case involves the claim of Eric Cruz, a former pretrial detainee at the Lubbock County Detention Center (LCDC), against Officer Domingo Cervantez. Cruz alleged that Cervantez violated his constitutional rights by showing deliberate indifference to his safety while he was enduring attacks from his cellmate. The jury agreed that Cervantez was deliberately indifferent but also decided that he was entitled to qualified immunity because he did not act unlawfully, considering the clearly established law and the information he had at the time. Cruz, now representing himself, argued that the district court erred in excluding evidence of disciplinary action taken against Cervantez following the incidents.The United States Court of Appeals for the Fifth Circuit, however, affirmed the district court's decision. Even if the lower court erred in excluding the disciplinary notice, Cruz failed to demonstrate that this error affected his substantial rights. The appellate court found that the disciplinary notice was largely duplicative of trial testimony and would have added very little to the evidence. Furthermore, it affirmed the jury's finding that a reasonable officer could have believed that Cruz was not in unreasonable danger, and thus Cervantez's actions were lawful in light of clearly established law and the information he possessed. View "Cruz v. Cervantez" on Justia Law

In this case before the United States Court of Appeals for the Fifth Circuit, the plaintiff, Lebene Konan, alleged that the United States Postal Service (USPS) employees intentionally withheld her mail for two years. Konan, who is African American, owned two properties in Texas that she rented out to tenants. She claimed that USPS employees, Jason Rojas and Raymond Drake, deliberately failed to deliver mail to these residences because they didn't like the idea of a black person owning those properties.Konan filed a lawsuit under the Federal Tort Claims Act (FTCA) and also alleged violations of her equal protection rights. The district court dismissed her claims due to lack of subject matter jurisdiction and failure to state a claim. Konan appealed the decision.The Appeals Court affirmed in part and reversed in part. It ruled that the district court erred in dismissing Konan's FTCA claim, finding that the postal-matter exception to the FTCA's immunity waiver did not apply to intentional acts such as those alleged. The court ruled that Konan's claims did not constitute a "loss," "miscarriage," or "negligent transmission" of mail, which are covered by the exception, as they involved intentional non-delivery of mail.However, the court agreed with the district court's dismissal of Konan's equal protection claims. The court held that Konan did not provide sufficient facts to support her assertion that the USPS employees continued to deliver mail to similarly situated white property owners while denying her mail delivery. It also held that her claims were barred by the intracorporate-conspiracy doctrine, which precludes conspiracy claims against multiple defendants employed by the same governmental entity. Therefore, the court affirmed the dismissal of Konan's equal protection claims. View "Konan v. USPS" on Justia Law

In the case considered by the United States Court of Appeals for the Fifth Circuit, employee Michael Ashford sued his former employer, Aeroframe Services, and Aviation Technical Services (ATS), alleging unpaid wages and other damages. The case, which began in Louisiana state court and was later removed to federal court, was complicated by numerous claims and counterclaims among the parties, including third-party defendant Roger Allen Porter, who was Aeroframe's sole principal.Initially, Ashford and other employees pursued claims against Aeroframe and ATS, alleging that negotiations between the two companies led to Aeroframe's insolvency and employees' loss of wages. ATS, in turn, cross-claimed against Aeroframe and Porter, alleging financial losses from its failed attempt to acquire Aeroframe. Porter also cross-claimed against ATS, asserting tortious interference and unfair trade practices.The Court of Appeals previously remanded the case to the district court, finding that the parties were not aligned in their interests at the time of the lawsuit's filing, and the district court lacked jurisdiction due to lack of diversity among the parties. Upon reconsideration, however, the district court found new evidence indicating that the interests of Aeroframe, Porter, and the employees were aligned from the inception of the litigation and that an irrevocable settlement agreement between them existed, allowing removal under the relevant law.The Court of Appeals affirmed the district court's ruling, finding that the non-ATS parties' interests were aligned from the litigation's inception. The Court also affirmed the district court's dismissal of all claims against ATS and the individual judgments against Aeroframe in favor of the employees. View "Ashford v. Aviation Technical Svc" on Justia Law

The case was heard in the United States Court of Appeals for the Fifth Circuit between former Blue Cube employee Elizabeth Cerda and her former employer, Blue Cube Operations, L.L.C. Cerda had been terminated for receiving pay for hours she did not work and threatening to expose her co-workers to COVID-19. She sued Blue Cube under the Family and Medical Leave Act (FMLA) and Title VII of the Civil Rights Act (Title VII). The district court granted summary judgment to Blue Cube, which Cerda appealed.The Appeals Court reviewed the case de novo and affirmed the district court's grant of summary judgment to Blue Cube. The Court found that Cerda failed to provide sufficient evidence for her FMLA claims. She did not adequately notify Blue Cube of her need or intent to take leave beyond her lunch breaks. The Court also dismissed Cerda's FMLA retaliation and Title VII sex discrimination claims due to lack of evidence of pretext. The Court found that Blue Cube had legitimate, non-retaliatory, and non-discriminatory reasons for terminating Cerda's employment.Furthermore, Cerda's Title VII sexual harassment claim was dismissed as she did not provide evidence that the harassment was based on her sex, was severe or pervasive enough to alter the conditions of her employment, or that Blue Cube had knowledge of the conduct. Lastly, the Court found no abuse of discretion in the district court's denial of Cerda's request to reconvene a deposition on a second day. Thus, the judgment of the district court was affirmed. View "Cerda v. Blue Cube Operations" on Justia Law