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

Albert McNeal, a convicted felon, pleaded guilty to possession of a firearm, violating federal law. He had a significant criminal history, including 18 convictions, seven of which were felonies, many involving violence and weapon use. His current conviction stemmed from an alleged aggravated assault with a deadly weapon and murder related to two separate shootings. The district court sentenced him to 60 months of incarceration and a three-year term of supervised release. McNeal challenged this sentence as procedurally erroneous.Prior to sentencing, the Probation Office recommended a four-point enhancement for using a weapon in connection with another felony offense. McNeal objected to this enhancement. The district court, however, decided that the Guidelines, with or without the enhancement, did not accurately reflect McNeal’s criminal history and the nature of his offense. The court concluded a variance was necessary to satisfy the sentencing factors. It declined to rule on the objection to the enhancement as unnecessary and chose a 60-month sentence that fell outside of the Guidelines system.McNeal appealed, arguing that his sentence was procedurally unreasonable because the district court did not rule on his objection to the enhancement. He contended that the court could not have calculated the applicable Guidelines range without ruling on the enhancement, making the court’s variance decision procedurally improper. The United States Court of Appeals for the Fifth Circuit disagreed, stating that the district court did calculate the applicable Guideline range and that any error was harmless. The court affirmed the district court's decision, stating that the district court made clear its decision to vary from the Guidelines. View "USA v. Mcneal" on Justia Law

The case involves Sharnez Hager, a Black woman, who along with her family, was denied immediate seating at a Chili's restaurant in Rosenberg, Texas, operated by Brinker Texas, Inc. The hostess informed them of a 45-minute wait despite an unoccupied large table being available. Later, Hager's white fiancé arrived and was immediately offered the same table. Hager and her family were eventually seated but received no service, leading them to leave the restaurant. Hager filed a lawsuit against Brinker, alleging racial discrimination under 42 U.S.C. §§ 1981, 1982, and Title II.The case was initially heard in a federal district court, where it was referred to a magistrate judge. Brinker moved for summary judgment, arguing that the delay in seating Hager's party was due to staff shortage, not racial discrimination. The magistrate judge recommended granting Brinker's motion for summary judgment, concluding that Hager failed to provide substantial evidence that Brinker's explanation was pretextual. The district court adopted the magistrate judge's recommendation and granted summary judgment in favor of Brinker.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court found that Hager had presented genuine disputes of material fact, including evidence of the hostess's apology for "discriminating against" her. The court also found that the magistrate judge erred in applying the McDonnell Douglas framework, a legal principle used to analyze claims of discrimination. The court concluded that the magistrate judge incorrectly classified the evidence, misapplied the burden-shifting framework, and improperly dismissed Hager's Title II claim based on her deposition testimony. The case was remanded for further proceedings. View "Hager v. Brinker Texas" on Justia Law

During the 2008 financial crisis, Highland Capital Management, L.P., an investment manager, faced numerous redemption requests from investors of the Highland Crusader Fund. The Fund was placed in wind-down, and a dispute arose over the distribution of assets. This led to the adoption of a Joint Plan of Distribution and the appointment of a Redeemer Committee to oversee the wind-down. The Committee accused Highland Capital of breaching its fiduciary duty by purchasing redemption claims of former investors. An arbitration panel ruled in favor of the Committee, ordering Highland Capital to pay approximately $3 million and either transfer or cancel the redemption claims.Before the Committee could obtain a judgment for the award, Highland Capital filed for Chapter 11 bankruptcy. CLO HoldCo, a creditor, filed a claim for approximately $11 million, asserting it had purchased interests in the redemption claims. However, after a settlement agreement between Highland Capital and the Committee led to the cancellation of the redemption claims, CLO HoldCo amended its claim to zero dollars.After the bankruptcy court confirmed Highland Capital's reorganization plan, CLO HoldCo filed a second amended proof of claim, asserting a new theory of recovery. It argued that the cancellation of the redemption claims resulted in a credit for Highland Capital, which it owed to CLO HoldCo. The bankruptcy court denied the motion to ratify the second amended proof of claim, a decision affirmed by the district court.The United States Court of Appeals for the Fifth Circuit affirmed the lower courts' decisions. It held that post-confirmation amendments require a heightened showing of "compelling circumstances," which CLO HoldCo failed to provide. The court found that the bankruptcy court did not abuse its discretion in denying CLO HoldCo's motion to ratify the second amended proof of claim. View "CLO Holdco v. Kirschner" on Justia Law

Rudy Naranjo, a federal prisoner, was serving concurrent 360-month sentences for multiple drug conspiracy offenses involving crack and powder cocaine, and a consecutive 120-month sentence for using and possessing a semiautomatic weapon in furtherance of the drug crime. He moved under Section 404 of the First Step Act of 2018 seeking a sentence reduction, which the district court denied. Naranjo then filed a second Section 404 motion. The district court dismissed that motion for lack of jurisdiction under Section 404(c) and, alternatively, denied the motion on the merits.Previously, Naranjo had been indicted on four counts of conspiring to and possessing with the intent to distribute crack and powder cocaine, and for knowingly using and possessing a semiautomatic weapon in furtherance of a drug trafficking crime. He was found guilty on all counts. After a series of post-conviction proceedings and appeals, Naranjo filed several motions challenging his sentence under the Fair Sentencing Act of 2010, all of which were denied. He then filed his first motion seeking relief under Section 404 of the First Step Act, arguing he was eligible for a sentence reduction. The district court denied this motion, concluding that Naranjo did not qualify for relief under the Fair Sentencing Act.In the United States Court of Appeals for the Fifth Circuit, Naranjo asserted that the district court erred when dismissing his second Section 404 motion for lack of jurisdiction. He also alleged that the district court should have reduced his sentence for his powder cocaine offense and should have analyzed the “full slate” of his arguments. The Court of Appeals held that Section 404(c) is a mandatory claim-processing rule, not a jurisdictional bar as the district court assumed. However, the Court of Appeals affirmed the district court's decision, concluding that Section 404(c)’s limitation on multiple motions must be enforced to bar Naranjo’s second Section 404 motion. View "USA v. Naranjo" on Justia Law

Buzzy Martinez was arrested and charged with transporting undocumented aliens hidden in his tractor-trailer after a U.S. Border Patrol (USBP) canine alerted to the vehicle. Martinez argued that the canine’s alerts could not provide the handler with the necessary reasonable suspicion to extend the stop of his vehicle and probable cause to search it because dogs are unable to reliably differentiate between the scents of a vehicle’s driver and concealed humans within the vehicle. The district court denied Martinez’s motion to suppress the evidence gathered from his vehicle, and he pleaded guilty while preserving his right to appeal the suppression ruling.The district court found that the USBP canine and its handler were adequately trained and certified to detect concealed humans, and that dogs are capable of detecting concealed humans. The court concluded that the canine’s alerts and indications were reliable, providing reasonable suspicion to extend the stop for a second sniff, and probable cause to search Martinez’s tractor-trailer after Martinez was removed from the vehicle. Martinez was sentenced to eighteen months in prison, followed by a term of supervised release of three years, and he appealed the ruling.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court held that the district court's finding that the canine was reliable in detecting concealed humans was not clearly erroneous. The court also noted that the canine was trained and certified to detect both concealed humans and controlled substances, and Martinez did not contest the canine's ability to detect controlled substances. Therefore, the canine's alert provided the handler with reasonable suspicion to investigate for and probable cause to search for controlled substances. The court concluded that the canine's alerts and indications at the primary inspection point provided reasonable suspicion to extend the stop and investigate for concealed humans, and at the secondary inspection point, after Martinez exited the vehicle and stated no one else was inside, the canine's continued alerts to the cab area of Martinez’s tractor-trailer provided probable cause to search the cab for concealed humans. View "United States v. Martinez" on Justia Law

The case revolves around a data privacy dispute involving Pebbles Martin and LCMC Health Holdings and Louisiana Children’s Medical Center (collectively, “LCMC”). Martin filed a class action suit alleging that LCMC violated Louisiana law by embedding tracking pixels onto its website that shared her private health information with third-party websites. The question before the court was not to determine the merits of Martin’s claims, but instead to determine which forum—state or federal—is proper to hear this dispute. LCMC argued that the suit should proceed in federal court because it acted under the direction of a federal officer when it allegedly violated Louisiana law. Martin, however, argued that the suit should remain in state court because LCMC fails to show a basis for federal jurisdiction.LCMC had removed the case to federal court, invoking the federal officer removal statute as the basis for jurisdiction. Martin moved to remand to state court, and the district court granted Martin’s motion, holding that LCMC did not act under the direction of a federal officer when it disclosed private health information to third-party websites. LCMC appealed the remand order.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court concluded that LCMC did not act under the direction of a federal officer when it embedded tracking pixels onto its website. The court noted that a hospital does not act under the direction of the federal government when it maintains an online patient portal that utilizes tracking pixels. Therefore, the federal officer removal statute does not provide jurisdiction for this case to be heard in federal court. The court affirmed the district court’s order remanding this case to state court. View "Martin v. LCMC Health Holdings" on Justia Law

The case involves the Roman Catholic Archdiocese of New Orleans ("Archdiocese") which sought Chapter 11 bankruptcy relief due to numerous lawsuits alleging sexual abuse by priests. The United States Trustee appointed an Official Committee of Unsecured Creditors ("Committee"), which included the appellants. The appellants' attorney, Richard Trahant, violated a protective order by disclosing confidential information related to abuse allegations against a priest. The bankruptcy court found Trahant's breach to be a disruption to the bankruptcy process and ordered the removal of Trahant's clients, the appellants, from the Committee.The appellants appealed their removal from the Committee to the district court, arguing that the district judge who was originally assigned their appeal should have recused himself earlier. The district court dismissed the appeal, concluding that the appellants lacked standing to appeal their removal from the Committee. The appellants then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision. It found that the district court did not err in declining to vacate the judgment, and the appellants lacked standing under Article III to prosecute this appeal. The court held that the appellants failed to demonstrate an injury to any legally protected interest. Their substantive rights as creditors in the bankruptcy case were not impaired by their removal from the Committee. The court also noted that the bankruptcy court's order did not amount to a personal sanction against the appellants, but was a consequence of the conduct of their attorney. View "Adams v. Roman Catholic Church" on Justia Law

This case involves a dispute between Sentry Insurance and James J. Morgan, who operates a business. Morgan's properties, insured by Sentry, suffered wind and hail damage from a storm. Sentry estimated the damages at $190,768.33 and paid Morgan $61,026.93 after deductions. However, Morgan estimated his loss at $540,426.05 and demanded Sentry pay an additional $349,657.22. When the parties couldn't agree on the loss amount, they turned to an appraisal process outlined in their insurance policy. Both parties appointed an appraiser, but the appraisers couldn't agree on an umpire. Consequently, Sentry filed a petition for the district court to appoint an umpire.The district court dismissed Sentry's petition, ruling that it lacked subject matter jurisdiction because the petition didn't meet the amount-in-controversy requirement for diversity jurisdiction under 28 U.S.C. § 1332. The court reasoned that it couldn't assess the value of the parties' contractual right to have an umpire examine the difference between two appraisers' estimates and determine the loss amount because the appraisers hadn't yet made their estimates.The United States Court of Appeals for the Fifth Circuit reversed the district court's decision. The appellate court disagreed with the district court's narrow interpretation of the right to be protected. It held that in an action seeking the appointment of an umpire for appraisal, the right to be protected is the right to continue with the appraisal process, and the value of this right is the disputed amount set to be resolved through appraisal. The court found that Sentry's petition established an amount in controversy over $75,000, as Morgan had demanded an additional $349,657.22 under the policy. The case was remanded to the district court to consider Morgan's additional jurisdictional arguments. View "Sentry Insurance v. Morgan" on Justia Law

DC Operating, a strip club in El Paso, Texas, and two of its employees, Nuvia Medina and Michelle Corral, challenged the constitutionality of S.B. 315, a Texas law that raised the minimum age of employment at sexually-oriented businesses from 18 to 21. The law was enacted to curb human trafficking. The plaintiffs argued that the law infringed on the employees' constitutional rights to expressive interest in nude dancing and occupational freedom. They also raised a claim of sex discrimination under the Equal Protection Clause for the first time on appeal.The United States District Court for the Western District of Texas upheld the constitutionality of S.B. 315, following similar rulings in other cases. The plaintiffs then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit dismissed the appeal for lack of jurisdiction. The court found that DC Operating lacked standing to bring the appeal because it did not assert any legal interests of its own, only those of its employees. The court noted that a plaintiff must assert its own legal rights and interests and cannot rest its claim to relief on the legal rights or interests of third parties. The court also found that the overbreadth claim brought by DC Operating did not alter the standing analysis because the plaintiff still needed to satisfy Article III requirements.Furthermore, the court found that the appeal was moot as to the two employees, Medina and Corral, because they had turned 21 and were no longer subject to the law they were challenging. The plaintiffs did not argue that the employees' claims remained justiciable or that an exception to mootness applied. Therefore, the court dismissed the appeal for lack of jurisdiction. View "DC Operating v. Paxton" on Justia Law

Dr. Randy Lamartiniere, an internal medicine doctor, was convicted of twenty counts of unlawful distribution of controlled substances. Lamartiniere had been practicing medicine for approximately thirty years and had a growing number of chronic pain patients. Concerns arose about his management of opioid and narcotic prescriptions and his inability to maintain timely patient records, leading to his termination from a clinic. He then opened his own practice, where a significant portion of his patients were pain management patients. The Drug Enforcement Administration (DEA) launched an investigation into his prescription practices, which included undercover agents posing as chronic pain patients. Lamartiniere was subsequently charged with twenty-eight counts of unlawful distribution of Schedule II controlled substances.At trial, the Government presented evidence from Lamartiniere’s former patients, undercover agents, and expert witnesses. Lamartiniere testified in his own defense, arguing that he was genuinely trying to treat his patients' legitimate medical conditions. The jury convicted Lamartiniere on twenty counts, and he was sentenced to 180 months per count, to run concurrently. Lamartiniere appealed, challenging the jury instructions and the sufficiency of the evidence supporting his convictions. The United States Court of Appeals for the Fifth Circuit affirmed the convictions, finding no reversible error. View "United States v. Lamartiniere" on Justia Law