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

Texas submitted a State Implementation Plan (SIP) to the Environmental Protection Agency (EPA) in 2012, asserting that its emissions did not significantly contribute to ozone pollution in downwind states and therefore no additional mitigation was necessary. The SIP included charts of declining ozone levels in certain metropolitan areas, a brief discussion of wind patterns, a map of 2010 ozone levels, and some raw measurement data, but did not analyze or quantify Texas’s impact on other states’ air quality. Texas’s submission focused on areas geographically close to Texas and did not address whether its emissions might interfere with maintenance of air quality standards in other states.After determining the SIP was technically complete, the EPA delayed substantive review pending the Supreme Court’s decision in EPA v. EME Homer City Generation, L.P., which clarified the agency’s authority under the Clean Air Act’s Good Neighbor Provision. During the delay, EPA provided Texas with updated modeling data showing that Texas emissions contributed to downwind ozone problems, but Texas did not supplement its SIP. In 2016, EPA formally disapproved the SIP, finding it failed to address statutory requirements, particularly by not evaluating impacts on maintenance areas and by relying on outdated control measures. Texas and industry groups petitioned the United States Court of Appeals for the Fifth Circuit for review, arguing EPA’s process was procedurally and substantively flawed.The United States Court of Appeals for the Fifth Circuit denied the petition. The court held that EPA’s review complied with statutory and procedural requirements, and that the agency acted within its authority in disapproving the SIP. The court found EPA’s reasoning was not arbitrary or capricious, and that the SIP’s failure to analyze Texas’s impact on all relevant downwind areas, including maintenance areas, justified disapproval. The court also rejected arguments that EPA was required to approve the SIP due to procedural delays or reliance on updated data. View "State of Texas v. EPA" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

A man incarcerated in Texas state prison was classified as a member of a security threat group and placed in administrative segregation, a form of solitary confinement, for sixteen years. The only way for him to return to the general prison population was to complete a gang renunciation program, which required him to renounce his gang affiliation and participate in an interview. During the interview, he was questioned by prison and law enforcement officials about criminal activities that occurred during his incarceration. He refused to answer questions that could incriminate him, after which his application to the renunciation program was terminated for failure to cooperate. He filed grievances challenging the process, but they were denied or dismissed.He then filed suit in the United States District Court for the Western District of Texas against several prison officials, alleging violations of his Fifth, First, and Fourteenth Amendment rights. The district court initially dismissed his claims, but the United States Court of Appeals for the Fifth Circuit vacated and remanded for further proceedings. After further litigation, including the appointment of counsel and discovery, the district court again granted summary judgment for the defendants, finding no constitutional violations and holding that the officials were entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the officials were entitled to qualified immunity on the Fifth Amendment self-incrimination and First Amendment compelled speech claims because there was no clearly established law making their conduct unlawful in this context. Regarding the Fourteenth Amendment procedural due process claim, the court assumed a liberty interest but found that the periodic classification reviews provided by the prison satisfied due process requirements. The court affirmed summary judgment in favor of the defendants. View "Ballentine v. Broxton" on Justia Law

Celia Ignacia Esquivel-Bataz, a Mexican citizen, was previously convicted of making a false statement to obtain credit and deported in 2012. In April 2025, she was found by ICE agents at an illegal gambling parlor in Houston. She was indicted for illegal reentry after deportation following a felony conviction, in violation of 8 U.S.C. § 1326(a) and (b). ICE lodged an immigration detainer against her, indicating that she would be taken into custody and removed to Mexico if released.A magistrate judge initially found that Esquivel-Bataz was not a flight risk and ordered her release on bond pending trial. The Government responded with an emergency motion to stay and revoke the release order, which the United States District Court for the Southern District of Texas granted. Esquivel-Bataz then moved for pretrial release, and the district court held an evidentiary hearing. After hearing testimony, including from an ICE officer about the detainer’s effect, the district court denied her motion, finding her to be a flight risk based on her criminal history, Mexican citizenship, prior deportation, and current unlawful presence.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s order under an abuse-of-discretion standard. The appellate court held that the district court did not abuse its discretion in denying pretrial release. The Fifth Circuit clarified that the district court did not treat the immigration detainer or potential deportation as flight risk per se, but rather considered the totality of circumstances, including individualized factors required by the Bail Reform Act. The order denying pretrial release was affirmed. View "United States v. Esquivel-Bataz" on Justia Law

WorldVue Connect, LLC, a company specializing in in-room entertainment and technology for hotels, purchased the domestic assets of Hospitality WiFi, LLC from Jason Szuch for $9,450,000 in 2022. Szuch retained interests in international affiliates and received a minority stake in a new entity, WorldVue Global, LLC. The transaction included the transfer of goodwill, trade secrets, and a valuable technical support team. In 2024, after the business relationship soured, WorldVue bought out Szuch’s minority interest and entered into a settlement agreement with Szuch and his companies, as well as a separation agreement with a key employee, Shan Griffin. These agreements, governed by Texas law, contained non-compete, non-solicitation, and confidentiality provisions effective for one year.Following the agreements, evidence emerged that the Szuch Parties recruited WorldVue’s employees and independent contractors, including those providing remote support to clients in the contractually defined “Restricted Area.” WorldVue filed suit in Texas state court for breach of contract and tortious interference, seeking injunctive relief. The state court issued a temporary restraining order, and after removal to the United States District Court for the Southern District of Texas, the TRO was extended. The district court found that the Szuch Parties breached the agreements by soliciting WorldVue’s workers and using confidential information, and granted a preliminary injunction prohibiting further solicitation and use of confidential information.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the preliminary injunction for abuse of discretion. The court affirmed the injunction, holding that the non-solicitation provision applied to workers performing services in the Restricted Area, regardless of their physical location, and that customer service agents were covered as independent contractors. The court modified the injunction to clarify that “confidential information” does not include Szuch’s personal knowledge of worker identities acquired prior to the asset sale. View "WorldVue Connect v. Szuch" on Justia Law

A group of drug manufacturers that participate in the federal Section 340B program challenged a Mississippi law, H.B. 728, which prohibits manufacturers from interfering with healthcare providers’ use of contract pharmacies to distribute discounted drugs to low-income and uninsured patients. The manufacturers argued that the law compels them to transfer drugs at a discount to private, for-profit pharmacies and expands their obligations under federal law, potentially enabling improper resale of discounted drugs. They sought a preliminary injunction to prevent the law from taking effect, claiming it constituted an unconstitutional taking and was preempted by federal law.The United States District Court for the Southern District of Mississippi denied the manufacturers’ motion for a preliminary injunction. The court found that the manufacturers had not demonstrated a substantial likelihood of success on the merits of their takings or preemption claims, and thus were not entitled to preliminary injunctive relief. The manufacturers appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion, applying clear error review to factual findings and de novo review to legal conclusions. The Fifth Circuit affirmed the district court’s decision, holding that the manufacturers had not shown a substantial likelihood of success on their claims. The court concluded that H.B. 728 did not effectuate a physical or regulatory taking, nor was it preempted by federal law under either field or conflict preemption theories. The court emphasized that, on the record presented, the manufacturers had not met their burden to justify the extraordinary remedy of a preliminary injunction. The district court’s denial of injunctive relief was therefore affirmed. View "AbbVie v. Fitch" on Justia Law

A group of former employees, most of whom are Black, brought claims against their former employer, an IT company, and its parent corporation. They alleged race discrimination, a hostile work environment, and retaliation for opposing discrimination, citing actions such as terminations, denials of promotions, and workplace policies they believed targeted Black employees. The plaintiffs described being subjected to stricter rules, surveillance, and less favorable treatment compared to non-Black employees. One plaintiff, who is white, also alleged retaliation for supporting his Black colleagues.The United States District Court for the Eastern District of Texas granted summary judgment to the employer on all hostile work environment claims and on certain discrimination and retaliation claims, finding insufficient evidence of an “ultimate employment decision” as required by then-controlling precedent. The court also excluded some witness testimony. At trial, a jury found for nine plaintiffs on discrimination and retaliation claims, awarding substantial damages. However, the district court granted judgment as a matter of law (JMOL) to the employer on most claims, finding insufficient evidence to support the jury’s verdicts, and to the parent company, concluding it was not an “integrated enterprise” with the employer. The court also granted a new trial on two retaliation claims, finding the verdicts contrary to the weight of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case. It vacated the summary judgment on certain discrimination and retaliation claims, remanding those for further proceedings in light of new precedent that broadened the definition of adverse employment actions. The Fifth Circuit affirmed the district court’s rulings in all other respects, including the grants of JMOL, the new trial orders, the exclusion of witness testimony, and the finding that the parent company was not liable as an integrated enterprise. View "Yarbrough v. SlashSupport" on Justia Law

After Hurricane Laura damaged an offshore platform owned by Genesis Energy, Genesis contracted with Danos, LLC to perform repairs. To support the project, Genesis also chartered a vessel from a third party to house and transport the repair crew and equipment. During the course of repairs, a Danos employee was injured while being transferred from the platform to the vessel and subsequently sued Danos, Genesis, and the vessel owner. Genesis filed a crossclaim against Danos, seeking defense and indemnification under a 2008 Master Services Agreement, arguing that the contract required Danos to indemnify Genesis for such claims.The United States District Court for the Southern District of Texas reviewed cross-motions for summary judgment from Genesis and Danos. The district court determined that the contract between Genesis and Danos was not a “maritime contract” under the Outer Continental Shelf Lands Act (OCSLA) and relevant Fifth Circuit precedent, specifically In re Larry Doiron, Inc. As a result, Louisiana law applied, which rendered the indemnification provision unenforceable. The district court granted summary judgment in favor of Danos, denied Genesis’s motion, and dismissed Genesis’s crossclaim with prejudice. The court’s order was designated as a final judgment under Federal Rule of Civil Procedure 54(b), and Genesis appealed.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The Fifth Circuit held that the contract was not a maritime contract because the parties did not expect the vessel to play a substantial role in the completion of the repair work; its functions were limited to transportation, housing, and ancillary support, which are insufficient under the applicable legal standard. The Fifth Circuit affirmed the district court’s judgment, holding that Louisiana law applied and the indemnification provision was unenforceable. View "Genesis Energy v. Danos" on Justia Law

A citizen of Mexico, who had been a lawful permanent resident in the United States since 1982, was convicted twice for aggravated assault with a deadly weapon—first in 2011 for shooting his ex-wife and again in 2018 for assaulting a roommate with a knife. These felony convictions led the Department of Homeland Security to initiate removal proceedings against him under Section 237(a)(2)(C) of the Immigration and Nationality Act, which concerns firearm offenses. An immigration judge ordered his removal after he completed his sentences, finding him ineligible for relief due to his convictions.The Board of Immigration Appeals (BIA) affirmed the removal order in 2020. The individual’s first petition for review to the United States Court of Appeals for the Fifth Circuit was dismissed as untimely. In 2022, he filed his first motion to reopen or reconsider with the BIA, arguing that a Supreme Court decision, Borden v. United States, changed the legal landscape regarding his removability. The BIA denied this motion, finding Borden inapplicable because his removal was based on a firearm offense, not an aggravated felony, and that the motion was untimely. In 2024, he filed a second motion to reopen, again citing Borden and seeking equitable tolling of both the time and numerical limits on motions to reopen. The BIA denied this second motion, holding that the statutory limit of one motion to reopen applied and that equitable tolling did not extend to the numerical bar.The United States Court of Appeals for the Fifth Circuit reviewed the BIA’s denial. The court held that the statutory “number bar” in the INA, which generally allows only one motion to reopen, is not subject to equitable tolling. The court dismissed the petition in part and denied it in part, concluding that the BIA did not err in refusing to reopen the removal proceedings. View "Garcia Morin v. Bondi" on Justia Law

A 78-year-old inmate in a Texas men’s prison, who identifies as a transgender woman, sought sex-reassignment surgery after being diagnosed with gender dysphoria in 2013. The inmate received hormone therapy and was chemically castrated, but was ultimately denied surgery by prison medical staff. The inmate alleged that state officials discriminated by providing reconstructive vaginoplasty to female inmates while denying similar surgery to transgender inmates, claiming a violation of the Equal Protection Clause.The United States District Court for the Southern District of Texas initially denied motions to dismiss based on sovereign immunity, finding that the inmate was similarly situated to cisgender female inmates and that the claims met the requirements of the Ex parte Young exception to sovereign immunity. On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit vacated the district court’s orders, holding that the inmate had not adequately pled that any defendant was sufficiently connected to enforcement of the challenged policy. On remand, after further proceedings and discovery, the district court granted judgment on the pleadings, concluding that the defendants were either improper under Ex parte Young or that the requested relief was not permitted, and dismissed the lawsuit for lack of jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal, holding that the inmate lacked standing. The court found that the alleged injury was not fairly traceable to the defendants, as there was no evidence that any treating physician had determined the inmate was a suitable candidate for surgery or would refer the inmate for the procedure. Without such evidence, the injury could not be redressed by a favorable judicial decision against the defendants. View "Haverkamp v. Linthicum" on Justia Law