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

Three organizations, Inclusive Louisiana, Mount Triumph Baptist Church, and RISE St. James, sued St. James Parish, the Parish Council, and the Parish Planning Commission, alleging violations of their constitutional and statutory civil rights. They claimed that the Parish discriminated against them by directing hazardous industrial development towards majority-Black districts and Black churches, where their members and congregants live. They also argued that the Parish's actions desecrated and restricted access to cemeteries of their enslaved ancestors.The United States District Court for the Eastern District of Louisiana dismissed all claims. It held that the plaintiffs lacked standing for some claims and that other claims were time-barred, as they were based on the Parish's 2014 Land Use Plan. The court also dismissed claims related to religious injuries, stating that the injuries were not traceable to the Parish's actions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in dismissing the claims as time-barred, noting that the plaintiffs alleged ongoing discriminatory practices, not just a single incident. The court also found that the plaintiffs had standing to sue for property injuries and health-related injuries. Additionally, the court held that the plaintiffs had standing to pursue claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Louisiana Constitution, as their alleged injuries were traceable to the Parish's conduct.The Fifth Circuit reversed the district court's dismissal of the claims and remanded the case for further proceedings. The court emphasized that the plaintiffs had sufficiently alleged ongoing discriminatory practices and injuries that were fairly traceable to the Parish's actions. View "Inclusive Louisiana v. St. James Parish" on Justia Law

Sharon Lewis, a former employee of Louisiana State University (LSU) football department, reported sexual harassment by former head football coach Les Miles and assistant coach Frank Wilson. She claimed retaliation for these reports, including exclusion from meetings, restructuring of her position, and eventual termination in 2022. Lewis filed a lawsuit under Titles IX and VII against the LSU Board of Supervisors, alleging retaliation and hostile work environment.The United States District Court for the Middle District of Louisiana held a six-day trial, after which the jury found in favor of the Board on all claims. The district court entered judgment accordingly. Lewis filed a renewed motion for judgment as a matter of law or, alternatively, for a new trial, which the district court denied. Lewis then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s judgment and denial of Lewis’s motions. The appellate court found that the jury had a legally sufficient evidentiary basis to conclude that Lewis’s termination was part of a broader restructuring initiative by new head coach Brian Kelly, rather than retaliation for her Title IX and Title VII complaints. The court noted that Kelly and other key decision-makers were unaware of Lewis’s prior complaints at the time of her termination. The court also found no abuse of discretion in the district court’s denial of a new trial, as the jury’s verdict was supported by the evidence presented. View "Lewis v. Board of Supervisors of Louisiana State University" on Justia Law

Scott Breimeister and four codefendants were tried for allegedly defrauding public and private healthcare programs of over $140 million through a scheme involving false claims for prescription drugs. During the trial, the Government made late disclosures of evidence favorable to the defense, affecting a significant portion of the testimony. The district court, concerned about the fairness of the trial, declared a mistrial sua sponte after determining that curative measures would not suffice to ensure a fair verdict.The United States District Court for the Southern District of Texas denied Breimeister's subsequent motion to bar retrial, finding that the Double Jeopardy Clause did not preclude a second trial because the mistrial was a "manifest necessity." Breimeister appealed this decision.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 Breimeister had impliedly consented to the mistrial by failing to object contemporaneously, and thus, the Double Jeopardy Clause did not bar retrial. Additionally, the court found that the district court did not abuse its discretion in declaring a mistrial due to manifest necessity, given the extensive impact of the Government's late disclosures on the trial's fairness. The appellate court concluded that the district court had carefully considered alternatives and acted within its discretion in declaring a mistrial. View "United States v. Breimeister" on Justia Law

A Texas state jury convicted Jesus Jaime Jimenez of organized crime involving violent robbery, and he was sentenced to 50 years in prison. Jimenez filed a federal habeas corpus petition, claiming his conviction was tainted by judicial bias due to the trial judge's relationship with the district attorney, who had misappropriated funds to pay for the judge's travel expenses.Jimenez first appealed his conviction through the Texas court system, where the Fourth Court of Appeals affirmed the jury's verdict, and the Texas Court of Criminal Appeals (TCCA) refused his petition for discretionary review. He then filed a state habeas corpus application, which was remanded by the TCCA to the trial court for findings on his claims of ineffective assistance of counsel, Brady violations, and judicial bias. The trial court rejected his claims, and the TCCA denied relief without a written order. Jimenez subsequently filed a federal habeas petition, which was initially denied as time-barred. However, the Fifth Circuit granted a certificate of appealability (COA), vacated the district court's decision, and remanded for further consideration. On remand, the district court again denied the petition as time-barred, but the Fifth Circuit found Jimenez entitled to equitable tolling and remanded for consideration on the merits. The district court ultimately denied relief on the merits, and Jimenez appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and denied Jimenez's habeas relief. The court held that the state court's adjudication of Jimenez's judicial-bias claim was not contrary to, nor an unreasonable application of, clearly established federal law. The court found that the trial judge's actions, while inappropriate, did not demonstrate actual or presumptive bias against Jimenez. The Fifth Circuit also denied Jimenez's motion to expand the COA to include his ineffective assistance of counsel and Brady claims, concluding that the district court's resolution of these claims was not debatable among jurists of reason. The court affirmed the district court's judgment and denied habeas relief. View "Jimenez v. Guerrero" on Justia Law

A Texas county judge, Brian Umphress, challenged the State Commission on Judicial Conduct's application of Canon 4A(1) of the Texas Code of Judicial Conduct, which requires judges to conduct their extra-judicial activities in a manner that does not call into question their impartiality. Umphress, who refuses to perform same-sex marriages for religious reasons while continuing to perform opposite-sex marriages, argued that applying the Canon to his refusal is unconstitutional. This challenge arose after a similar situation involving Justice of the Peace Dianne Hensley, who was publicly warned by the Commission for her refusal to perform same-sex weddings.The United States District Court for the Northern District of Texas dismissed Umphress's case for lack of subject matter jurisdiction, holding that he lacked standing and that his claims were not ripe. The court also noted that even if it had jurisdiction, it would have abstained under the Pullman doctrine, which allows federal courts to defer to state courts on issues of unclear state law.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that Umphress had standing and that his claims were ripe for review. The court held that Umphress had demonstrated an imminent injury in fact, as his intended conduct was arguably proscribed by Canon 4A(1) and there was a substantial threat of future enforcement by the Commission. The court also determined that the case was not moot despite the Commission's rescission of its warning against Hensley, as the Commission had not disavowed future enforcement against Umphress.The Fifth Circuit reversed the district court's dismissal and declined to abstain under Pullman, noting that state court litigation was unlikely to resolve the crucial threshold question of Texas law. Instead, the court certified the question to the Supreme Court of Texas, asking whether Canon 4A(1) prohibits judges from publicly refusing to perform same-sex weddings for moral or religious reasons while continuing to perform opposite-sex weddings. View "Umphress v. Hall" on Justia Law

Gustavo Santander and his wife visited a sports bar in Fort Worth, Texas, where Jose Salazar, an off-duty police officer working as a security guard, allegedly pushed Santander without provocation, causing him to fall. When Santander confronted Salazar, Salazar allegedly punched him multiple times, leading to his arrest for public intoxication. The charge was later dismissed, and an internal review by the Fort Worth Police Department concluded that Salazar had violated departmental rules, resulting in his termination. Santander then filed a lawsuit under 42 U.S.C. § 1983, claiming excessive force, false arrest, and malicious prosecution.The United States District Court for the Northern District of Texas dismissed Santander’s claims with prejudice, stating that he failed to cite relevant legal authority to support his claims and did not show that Salazar violated any clearly established rights. Santander appealed the decision, arguing that the district court erred in its judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that the district court applied an incorrect pleading standard by requiring Santander to substantiate his claims with legal authority in his complaint. The appellate court held that Santander’s excessive force claim was plausible and could defeat Salazar’s qualified immunity at the pleading stage. However, the court affirmed the dismissal of Santander’s false arrest and malicious prosecution claims, as he could not show that Salazar violated clearly established law regarding these claims.The Fifth Circuit affirmed the district court’s dismissal of the false arrest and malicious prosecution claims but reversed the dismissal of the excessive force claim, remanding it for further proceedings. View "Santander v. Salazar" on Justia Law

William Maxwell, a federal prisoner, filed a 28 U.S.C. § 2241 petition for writ of habeas corpus, seeking transfer to a halfway house or home confinement under the First Step Act of 2018. He argued that the district court erred in determining that he failed to exhaust administrative remedies.The United States District Court for the Eastern District of Texas dismissed Maxwell's petition, concluding that he had not exhausted his administrative remedies. Maxwell appealed this decision, contending that the district court's determination was incorrect.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Maxwell's request for transfer to a halfway house or home confinement did not entitle him to accelerated release. According to the court's precedent in Melot v. Bergami, such relief should be sought through a civil rights suit rather than a habeas petition. Consequently, the court did not address whether Maxwell had exhausted his administrative remedies, as the proper vehicle for his claim was a civil rights suit, not a habeas petition. The court affirmed the district court's dismissal of Maxwell's petition. View "Maxwell v. Thomas" on Justia Law

In 2018, DeWolff, Boberg & Associates, Inc. (DB&A), a management consulting firm, hired Justin Pethick as a regional vice president of sales. In 2020, Pethick accepted a job offer from The Randall Powers Company (the Powers Co.), a competitor. After Pethick joined the Powers Co., some prospective DB&A clients hired the Powers Co. DB&A alleged that Pethick stole its trade secrets and used them to poach clients.The United States District Court for the Northern District of Texas excluded DB&A’s damages expert under Daubert v. Merrell Dow Pharmaceuticals, Inc., and granted summary judgment to the defendants, citing DB&A’s lack of evidence of damages. DB&A appealed, contesting the exclusion of its expert and the summary judgment on its misappropriation of trade secrets claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that to prevail on a misappropriation of trade secrets claim under Texas law, a plaintiff must show that a trade secret existed, it was acquired through a breach of a confidential relationship or discovered by improper means, and the defendant used the trade secret without authorization. The court found that DB&A failed to identify specific trade secrets within its databases and did not provide evidence that Pethick or the Powers Co. used or disclosed any trade secrets. Consequently, the court affirmed the summary judgment dismissal of DB&A’s misappropriation claim on these alternative grounds. View "DeWolff, Boberg & Associates, Inc. v. Pethick" on Justia Law

Former employees of Shriners Hospitals for Children were terminated for refusing to get a COVID-19 vaccination. They sued their employer, its agents, and the Executive Commissioner of Texas Health and Human Services, alleging violations of their right to refuse the vaccine under 42 U.S.C. § 1983, the Emergency Use Authorization (EUA) Statute, and various Texas state laws.The United States District Court for the Southern District of Texas dismissed all claims. It found no personal jurisdiction over the agents due to the fiduciary shield doctrine, determined that Shriners was not a state actor when it implemented the vaccination policy, and ruled that the EUA Statute did not apply. The court also dismissed the claims against the Commissioner, concluding she was not liable for failing to stop Shriners from enforcing the policy. The state-law claims were dismissed for lack of supplemental jurisdiction.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It agreed that there was no personal jurisdiction over the agents and that Shriners was not a state actor when it adopted the vaccination policy. The court also held that the EUA Statute did not apply to Shriners in its capacity as an employer and that the Commissioner was entitled to qualified immunity because the plaintiffs did not demonstrate a clearly established right requiring her intervention. The appellate court modified the dismissal of the state-law claims to be without prejudice and affirmed the judgment as modified. View "Pearson v. Shriners Hospitals" on Justia Law

The Bureau of Ocean Energy Management (BOEM) adopted a rule requiring current lessees of offshore drilling facilities in the Gulf of Mexico to obtain financial assurance bonds to cover potential future decommissioning liabilities. Several states and industry groups sued to vacate the rule, arguing it imposed undue financial burdens. The American Petroleum Institute (API), representing a broad range of oil and gas companies, sought to intervene in defense of the rule, claiming its members had unique interests in upholding it.The United States District Court for the Western District of Louisiana denied API's motion to intervene. The court found the motion procedurally defective because API did not attach a proposed answer to its motion, as required by local rules. Substantively, the court concluded that API failed to demonstrate that BOEM would inadequately represent its interests, a necessary showing for intervention as of right. The court also denied permissive intervention, suggesting that API could present its unique perspective through an amicus brief instead.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of API's motion to intervene. It held that API did not overcome the presumption that BOEM adequately represented its interests, as API failed to show any specific adversity of interest or actions by BOEM that were contrary to API's interests. The court also found no abuse of discretion in the district court's denial of permissive intervention, agreeing that API could effectively present its views as an amicus curiae. Thus, the district court's order denying intervention was affirmed. View "Louisiana v. Burgum" on Justia Law