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

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

In this case, Austin Thompson Hughes, a former police officer and Uber driver, reported a drunk driver swerving across a highway in Houston. After the drunk driver crashed, Hughes, still on the phone with 911, performed a citizen's arrest in accordance with Texas law. However, when police officers arrived at the scene, they released the drunk driver and arrested Hughes, charging him with a felony for impersonating a peace officer. Hughes spent thousands of dollars defending against these charges before they were dropped by the City of Houston. Hughes then filed a § 1983 suit against the two officers who arrested him.The case was initially heard in the United States District Court for the Southern District of Texas, where the officers moved to dismiss Hughes's complaint, asserting qualified immunity. The district court denied the officers' motions, leading to an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision, denying the officers' qualified immunity. The court found that Hughes had sufficiently pleaded that the officers violated his Fourth Amendment rights by arresting and prosecuting him without probable cause because they included material misstatements and omissions in their warrant affidavit and materials. The court also found that a corrected warrant affidavit could not have established probable cause to arrest and prosecute Hughes. The court concluded that no reasonable officer could have suspected Hughes committed a felony, given the inconsistencies in the drunk driver's statement, the driver's obvious intoxication, and the evidence supporting Hughes's account. View "Hughes v. Garcia" on Justia Law

Sonia Rangel and her two minor children, Luisa and Mary Loredo, citizens of Mexico who entered the United States illegally, sought asylum, withholding of removal, and relief under the Convention Against Torture (CAT). They claimed they should be protected from removal due to their belief that the Mexican Navy would persecute and torture them to dissuade Rangel from her campaign against the Mexican military for the disappearance of her son. The Immigration Judge (I.J.) denied their applications, finding they had not established past persecution or a well-founded fear of future persecution, and were not eligible for CAT relief due to failure to establish the requisite likelihood of future torture. The Board of Immigration Appeals (BIA) affirmed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the BIA's factual findings under the substantial evidence standard and its legal conclusions de novo. The court found that the evidence did not compel a conclusion that the petitioners had suffered past persecution or had a well-founded fear of future persecution. The court also found that the petitioners had not met the higher bar of showing it was more likely than not they would be tortured upon return to Mexico, which is required for CAT relief. Therefore, the court denied the petition for review, upholding the BIA's decision to deny the applications for asylum, withholding of removal, and CAT relief. View "Loredo Rangel v. Garland" on Justia Law

The case involves Kholkar Vishveshwar Ganpat, an Indian citizen, who contracted malaria while working as a crew member on a Liberian-flagged ship managed by Eastern Pacific Shipping Pte., Limited (EPS), a Singaporean company. Ganpat alleges that EPS failed to adequately provision the ship with antimalarial medication for its voyage to Gabon, a high-risk malaria area in Africa. Ganpat's illness resulted in gangrene, amputation of several toes, and a 76-day hospitalization. He filed a lawsuit against EPS in the United States, seeking relief under the Jones Act and the general maritime law of the United States. He also asserted a contractual claim for disability benefits.The district court initially deferred making a choice-of-law ruling. However, after discovery, the court ruled that the law of the United States (the Jones Act and general maritime law) governs Ganpat’s tort claims and claim for breach of the collective bargaining agreement. EPS appealed this decision.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 assessment of the Lauritzen-Rhoditis factors, which are used to determine whether maritime claims are governed by the law of the United States or the conflicting law of a foreign nation. The appellate court found that none of the factors that the Supreme Court has deemed significant to the choice-of-law determination in traditional maritime shipping cases involve the United States. The court concluded that Ganpat’s maritime tort and contract claims should be adjudicated under the substantive law of Liberia, the flag state of the ship on which Ganpat was working when he contracted malaria. The case was remanded for further proceedings consistent with this opinion. View "Ganpat v. Eastern Pacific Shipping" on Justia Law

Levi Rudder, a non-lawyer, was sanctioned by the United States District Court for the Northern District of Texas for engaging in unauthorized practice of law. Rudder had contacted a detainee facing federal firearm charges and attempted to involve himself in the case, despite being told not to by the defense counsel. He held an unprivileged, monitored video meeting with the detainee, offered legal advice, and encouraged the detainee to sign a form appointing him as additional counsel. The district court found Rudder guilty of unauthorized practice of law and imposed a monetary sanction of $500. He was also barred from filing documents in the Northern District of Texas without the court's permission.Rudder appealed the decision, arguing that the district court lacked the authority to impose these sanctions. He contended that the Constitution does not afford federal courts inherent powers to sanction individuals for engaging in unauthorized practice of law.The United States Court of Appeals for the Fifth Circuit disagreed with Rudder's argument. The court cited previous cases that established federal courts' inherent power to police the conduct of litigants and attorneys who appear before them. The court also noted that a party cannot be represented by a non-lawyer and that a minimum level of competence is required to protect the client, their adversaries, and the court from poorly drafted, inarticulate, or vexatious claims. Therefore, the court concluded that a federal court's power to regulate and discipline attorneys extends to conduct by non-lawyers amounting to practicing law without a license. The court found that the district court did not abuse its discretion in imposing the sanctions on Rudder and affirmed the lower court's decision. View "In re: Rudder" on Justia Law

The case involves a dispute between BMC Software, Inc. (BMC) and International Business Machines Corporation (IBM) over a Master Licensing Agreement (MLA) and an Outsourcing Attachment. BMC, a software company, and IBM, an information technology company, directly compete in developing and selling mainframe software. However, IBM also provides necessary outsourcing services to BMC and its customers, including AT&T. In 2008, IBM and BMC entered into an MLA and an Outsourcing Attachment, which were amended in 2013 and 2015. The dispute centers around the 2015 amendment, particularly three provisions that govern IBM's use of BMC's software.The case was first heard in the United States District Court for the Southern District of Texas. The district court awarded summary judgment to IBM on the claim for breach of Section 1.1 of the 2015 amendment, but denied IBM's motion for summary judgment on BMC’s Section 5.1 breach-of-contract claim. The court concluded that Section 5.4 of the 2015 amendment unambiguously prevented IBM from “displacing” BMC products with IBM software. The court granted partial summary judgment to BMC because IBM “displaced BMC Customer Licenses with IBM products when it implemented Project Swallowtail at AT&T.” After a bench trial, the district court awarded BMC approximately $1.6 billion in damages.The case was then appealed to the United States Court of Appeals for the Fifth Circuit. The appellate court disagreed with the district court's interpretation of Section 5.4 of the 2015 amendment. The court held that “other valid business reasons” under Section 5.4 supported IBM’s service in effecting AT&T’s switchover, which partially included IBM software. The court concluded that IBM did not breach Section 5.4 by agreeing to provide IT services to perform this task. Therefore, the judgment of the district court was reversed. View "BMC Software v. IBM" on Justia Law

The case involves a challenge by the Sierra Club to the pre-construction permits issued by the Louisiana Department of Environmental Quality (LDEQ) to Commonwealth LNG, LLC for its planned liquefied natural gas (LNG) export facility. The Sierra Club argued that the facility’s emissions would exceed National Ambient Air Quality Standards (NAAQS) and that LDEQ failed to require Commonwealth to use the best available control technology (BACT) to limit those emissions.Before the United States Court of Appeals for the Fifth Circuit, LDEQ argued that the court lacked jurisdiction to hear the case, asserting that the claim arose under state law, not federal law. However, the court found that it had jurisdiction to review the petition because when LDEQ issued the permit, it was acting pursuant to federal law, not merely state law.On the merits, the court found that LDEQ did not act arbitrarily in its use of significant impact levels (SILs) to calculate which pollutants will have an insignificant effect on the NAAQS. The court also found that LDEQ did not act arbitrarily in its use of AP-42 emission factors to determine potential emissions from an LNG facility that has not yet been built. Furthermore, the court held that LDEQ did not violate its public trustee duty under Louisiana law, which requires LDEQ to evaluate and avoid adverse environmental impacts to the maximum extent possible.The court denied Sierra Club’s petition for review and affirmed LDEQ’s permitting decision. View "Sierra Club v. Louisiana Department of Environmental Quality" on Justia Law