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

Caris MPI, Inc. (Caris) provided cancer diagnostic services to UnitedHealthcare, Inc. (United) for over ten years without a written contract. United audited Caris’s past claims and determined that Caris had used incorrect billing codes, resulting in overpayments. United began recouping these overpayments by offsetting them against new payment claims from Caris. Caris challenged United’s recoupment through United’s internal process, but after United rejected Caris’s appeals, Caris filed suit in Texas state court alleging various state law claims.United removed the case to the United States District Court for the Northern District of Texas, asserting federal officer jurisdiction under 28 U.S.C. § 1442(a)(1). The district court denied Caris’s motion to remand and dismissed Caris’s claims without prejudice, finding that Caris failed to exhaust administrative remedies under the Medicare Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and agreed that federal officer jurisdiction existed. However, the court found that the district court erred in dismissing Caris’s claims for failure to exhaust administrative remedies. The Fifth Circuit held that the administrative review process under Medicare Part C does not extend to claims where an enrollee has no interest, and there were no administrative remedies for Caris to exhaust. The court distinguished this case from others by noting that no enrollee had requested an organization determination or appeal, and all enrollees had already received the services for which United sought recoupment. Consequently, the court affirmed the denial of the remand motion, reversed the dismissal of Caris’s claims, and remanded the case for further proceedings. View "Caris MPI v. UnitedHealthcare, Incorporated" on Justia Law

Dobbin Plantersville Water Supply Corporation (Dobbin) held a Certificate of Convenience and Necessity (CCN) to provide water service in certain areas of Texas. Dobbin, a recipient of federal loans under 7 U.S.C. § 1926, which grants monopoly protection to loan recipients, faced decertification petitions from developers SIG Magnolia L.P. and Redbird Development L.L.C. The Public Utility Commission of Texas (PUC) granted these petitions, finding that Dobbin was not providing actual water service to the developers' properties. Dobbin then filed a lawsuit in federal court, arguing that the Texas Water Code section allowing decertification was preempted by federal law.The United States District Court for the Western District of Texas dismissed Dobbin's 42 U.S.C. § 1983 claims against the PUC officials, concluding they were not appropriate defendants under § 1983. At the summary judgment stage, the district court dismissed Dobbin's remaining claims with prejudice, primarily on jurisdictional grounds. The court found that Dobbin lacked a cause of action against the developers and that an injunction against the PUC would not redress Dobbin's injuries.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 Dobbin lacked standing to seek an injunction against the PUC officials because such relief would not redress its injuries. The court also upheld the dismissal of Dobbin's § 1983 claim against the PUC officials, reiterating that state officials in their official capacities are not "persons" under § 1983. Lastly, the court found no abuse of discretion in the district court's decision to dismiss Dobbin's claims against the developers with prejudice, as Dobbin lacked a viable cause of action against them. View "Dobbin Plantersville Water Supply Corporation v. Lake" on Justia Law

The case involves the Canadian Standards Association (CSA), a Canadian not-for-profit corporation that holds Canadian copyrights for various model codes. CSA alleged that P.S. Knight Company, Limited, PS Knight Americas, Incorporated, and Gordon Knight (collectively, Knight) infringed its copyrights by selling competing versions of CSA’s codes. These codes had been incorporated by reference into Canadian statutes and regulations. Knight argued that his actions were permissible under U.S. copyright law, as the codes had become "the law" of Canada.The United States District Court for the Western District of Texas found in favor of CSA, granting its motion for summary judgment and issuing a permanent injunction against Knight. The district court held that Knight's copying of CSA’s codes constituted copyright infringement and declared Knight’s U.S. copyright registration invalid. Knight appealed the decision, arguing that the district court improperly applied the law.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that the district court had improperly applied the holding of Veeck v. Southern Building Code Congress International, Inc., which states that once model codes are enacted into law, they become "the law" and may be reproduced or distributed as such. The Fifth Circuit held that because CSA’s model codes had been incorporated into Canadian law, Knight’s copying of those codes did not constitute copyright infringement under U.S. law.The Fifth Circuit reversed the district court’s summary judgment decisions, vacated the grant of injunctive relief, and remanded the case with instructions to grant summary judgment in favor of Knight and to dismiss CSA’s copyright infringement claim. View "Canadian Standards Association v. P.S. Knight Company Limited" on Justia Law

During Winter Storm Uri in 2021, Pioneer Natural Resources invoked a force majeure clause to excuse its failure to deliver natural gas to MIECO, L.L.C., as per their contract. MIECO sued for damages, arguing that Pioneer improperly invoked the clause. The federal district court granted summary judgment in favor of Pioneer, ruling that the force majeure clause was correctly invoked and did not require Pioneer to show that the storm made performance literally impossible. The court also held that Pioneer’s “gas supply” referred only to gas it regularly produced from the Permian Basin, not substitute gas available on the spot market.The United States District Court for the Northern District of Texas initially reviewed the case. The court found that the force majeure clause was unambiguous and did not require Pioneer to purchase available spot market gas. It rejected MIECO’s argument that a force majeure event must render performance literally impossible and that “Seller’s gas supply” included spot market gas. The court granted summary judgment for Pioneer, dismissing MIECO’s breach of contract claim.The United States Court of Appeals for the Fifth Circuit reviewed the case on appeal. The appellate court affirmed the district court’s interpretation of the force majeure clause, agreeing that it did not require performance to be literally impossible and that “Seller’s gas supply” referred only to gas produced from the Permian Basin. However, the appellate court found that the district court erred by not addressing whether Pioneer exercised due diligence to overcome the storm’s impact. The appellate court held that genuine disputes of material fact remained regarding whether Pioneer made reasonable efforts to avoid the adverse impacts of the storm. Consequently, the appellate court affirmed in part, reversed in part, and remanded the case for further proceedings to resolve these factual disputes. View "Mieco, L.L.C. v. Pioneer Natural Resources USA, Incorporated" on Justia Law

Joel Francois Jean was incarcerated in Texas since 2009 after pleading guilty to conspiracy to possess with intent to distribute cocaine and possession of a firearm in furtherance of a drug-trafficking offense. At sentencing, he was classified as a career offender due to three prior Texas controlled-substance convictions, resulting in a Guidelines range of 352 to 425 months, but he received a 292-month sentence. Subsequent legal decisions (Mathis v. United States, United States v. Hinkle, and United States v. Tanksley) redefined what constitutes a controlled-substance offense, meaning Jean would not be classified as a career offender if sentenced today.Jean filed a motion for compassionate release in 2023, arguing that changes in the law, sentence disparities, and his rehabilitation warranted release. The district court found that the non-retroactive changes in the law, combined with Jean's extraordinary rehabilitation, constituted extraordinary and compelling reasons for compassionate release. The court noted Jean's significant efforts towards self-improvement and the support he received from Bureau of Prisons officials. Consequently, Jean was resentenced to time served, followed by eight years of supervised release.The United States appealed the district court's decision. The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's grant of compassionate release. The appellate court held that district courts have the discretion to consider non-retroactive changes in the law, along with other factors such as extraordinary rehabilitation, when determining whether extraordinary and compelling reasons exist for compassionate release. The court emphasized that this discretion is consistent with Supreme Court precedent and Congressional intent, and noted that the Sentencing Commission's November 1, 2023 Amendments support this interpretation. View "USA v. Jean" on Justia Law

Joshua Jones applied for disability insurance benefits (DIB) and supplemental security income (SSI) on October 1, 2019, citing various medical conditions including disc herniation, diabetes, and high blood pressure. His applications were denied initially and upon reconsideration. Jones then requested a hearing before an administrative law judge (ALJ), which took place on August 5, 2021. The ALJ denied his claims on October 6, 2021. Jones appealed to the Appeals Council, which denied review. Subsequently, he sought judicial review in the United States District Court for the Eastern District of Louisiana, which upheld the Commissioner’s decision.The district court reviewed cross-motions for summary judgment and adopted the magistrate judge’s recommendation to deny Jones’ motion and grant the Commissioner’s motion. The court found that the ALJ had applied the correct legal standards and that substantial evidence supported the decision. Jones then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court’s judgment. The court held that the ALJ correctly applied Listing 1.15, which became effective on April 2, 2021, rather than the older Listing 1.04, to evaluate Jones’ claims. The court found that applying the new listing to pending claims did not constitute impermissible retroactivity. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence, including the finding that Jones did not meet the criteria for medical equivalency under Listing 1.15. The court also concluded that the ALJ properly considered the impact of Jones’ medical treatments on his ability to maintain employment, finding no evidence that his treatment regimen significantly interrupted his ability to work. View "Jones v. O'Malley" on Justia Law

Plaintiffs-Appellants, a group of produce suppliers, sold produce to Lonestar Produce Express, LLC, a produce broker started by Leonidez Fernandez III and Eric Fernandez. Their father, Leonidez Fernandez Jr., frequently assisted them. By mid-2019, Lonestar owed approximately $221,000 to Plaintiffs-Appellants for unpaid produce invoices. Plaintiffs-Appellants sought relief under the Perishable Agricultural Commodities Act (PACA), which requires produce buyers to hold produce or proceeds from its sale in trust for unpaid suppliers until full payment is made. If the merchant's assets are insufficient, others who had a role in causing the breach of trust may be held secondarily liable.The United States District Court for the Western District of Texas held a bench trial to determine whether Leonidez Fernandez Jr. could be held individually liable under PACA. The court found that Leonidez Jr. was not a member, manager, or employee of Lonestar and did not have control over its financial operations. Consequently, the district court concluded that Leonidez Jr. did not owe a fiduciary duty under PACA and was not liable for Lonestar's debts.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that individuals who are not members of an LLC can still be held secondarily liable under PACA if they have control over the trust assets. However, the court found that Leonidez Jr. did not have the requisite control over Lonestar's PACA trust assets. He was not authorized to direct payments, was not a signatory on the bank account, and did not contribute financially to Lonestar. Therefore, the Fifth Circuit affirmed the district court's decision, concluding that Leonidez Jr. was not liable under PACA. View "A & A Concepts v. Fernandez" on Justia Law

John Craig First purchased an agricultural combine from Rolling Plains Implement Company, which was manufactured by AGCO Corporation. First was told the combine was part of AGCO’s Certified Pre-Owned Program, had roughly 400 hours of use, and had never been to the field. However, these representations were false; the combine was not certified and had over 1,200 hours of use. After experiencing numerous issues with the combine, First discovered in 2019 that it had an extensive repair history and over 900 hours of use. He then filed a lawsuit against Rolling Plains, AGCO Corporation, AGCO Service, AGCO Finance, and other related entities.Initially, First filed his lawsuit in the District Court of Oklahoma County, but it was removed to federal court in Oklahoma, which dismissed the case without prejudice and transferred it to the Northern District of Texas. First amended his complaint multiple times, asserting claims of fraud, breach of warranty, and failure of essential purpose. The district court dismissed the fraud claims against AGCO Corporation, AGCO Service, and AGCO Finance for lack of particularity and granted summary judgment in favor of AGCO Finance on the warranty claims. The case proceeded to trial on the remaining claims, where the jury found that First knew or should have known of the fraud by April 13, 2017, and awarded him $96,000 in damages. However, the district court entered judgment in favor of Rolling Plains based on the statute of limitations.The United States Court of Appeals for the Fifth Circuit reviewed the case. It vacated the district court’s judgment as a matter of law in favor of Rolling Plains, finding insufficient evidence to support the jury’s selected date for the statute of limitations. The case was remanded for retrial on when First’s cause of action accrued. The appellate court affirmed the dismissal of fraud claims against AGCO Corporation, AGCO Service, and AGCO Finance, and upheld the summary judgment in favor of AGCO Finance on the warranty claims. View "First v. Rolling Plains Implement Co." on Justia Law

Salvador Jaquez was convicted by a jury of conspiracy to transport an undocumented alien and transporting or attempting to transport an undocumented alien within the United States. The charges stemmed from an incident where Jaquez was found in a truck with undocumented aliens hidden in a trailer. The truck was intercepted by Border Patrol agents near Laredo, Texas, after being detected by surveillance cameras. Jaquez was the only U.S. citizen in the vehicle, and various incriminating items were found in the truck, including cell phones, bolt cutters, and master locks.The United States District Court for the Southern District of Texas handled the initial trial. Jaquez pled not guilty, but the jury found him guilty on both counts. The district court sentenced him to concurrent 36-month prison terms followed by three years of supervised release. Jaquez appealed, challenging the sufficiency of the evidence for both convictions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court examined whether the evidence presented at trial was sufficient to support the jury's verdict. For the conspiracy charge, the court found that Jaquez's inconsistent statements, his knowledge of the smuggling operation, and his communications with a contact named Edgar Descargas provided sufficient circumstantial evidence of an agreement to transport undocumented aliens. For the transporting charge, the court determined that Jaquez's role in the operation, including his possession of the locks and keys and his coordination efforts, demonstrated sufficient control over the means of transportation.The Fifth Circuit concluded that a rational juror could find Jaquez guilty beyond a reasonable doubt on both counts. The court affirmed the district court's judgment, upholding Jaquez's convictions and sentences. View "United States v. Jaquez" on Justia Law

The case involves Lion Elastomers, a synthetic rubber manufacturer, and the National Labor Relations Board (NLRB). Lion Elastomers had been found guilty of unfair labor practices by the NLRB for threatening, disciplining, and discharging an employee, Joseph Colone, for engaging in protected activities. The NLRB applied the Atlantic Steel standard to assess whether Colone's behavior lost its protected status. However, before the appeal of the Board’s decision had been briefed, the NLRB issued a new interpretation of the National Labor Relations Act (NLRA) in a case called General Motors, which overruled Atlantic Steel. The NLRB then sought a remand to apply this new interpretation to the Lion Elastomers case.The case was remanded to the NLRB by the Fifth Circuit Court of Appeals. However, instead of applying the new interpretation from General Motors as expected, the NLRB used the remand proceeding to overrule General Motors and return to the Atlantic Steel standard. Lion Elastomers argued that the NLRB exceeded the scope of the remand and violated its due-process rights during the remand proceeding.The Fifth Circuit Court of Appeals agreed with Lion Elastomers. The court found that the NLRB had exceeded the scope of the remand by not applying the General Motors standard as expected. The court also found that the NLRB had violated Lion Elastomers's due-process rights by not giving the company an opportunity to be heard before deciding to overturn General Motors. The court vacated the NLRB's decision and remanded the case back to the NLRB, instructing it to apply the General Motors standard to this case. View "Lion Elastomers v. National Labor Relations Board" on Justia Law