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

A police officer, David Stanley, was suspended and transferred by the Lafayette Police Department (LPD) following an investigation into his Facebook posts. Stanley took sick leave for about a year and appealed his suspension to the Municipal Fire and Police Civil Service Board. He also filed two petitions in state court seeking to enjoin the suspension and transfer. The state district court granted a temporary restraining order (TRO), but the state appellate court dismissed LPD’s appeal of the TRO. Stanley re-filed his petition, but the state district court found he needed to finalize his appeal with the Civil Service Board first. The Civil Service Board later reduced his suspension but upheld his transfer.Stanley then filed a lawsuit in federal district court under 42 U.S.C. § 1983, alleging First Amendment violations and retaliation. The district court dismissed his claims as time-barred, determining that the one-year prescriptive period began when Stanley was notified of his suspension on June 11, 2021. The court also concluded that Stanley’s state court petitions did not interrupt the prescription period because they did not assert federal claims or seek monetary damages.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Stanley’s § 1983 claims accrued when he received notice of the adverse actions, not when the administrative appeal concluded. The court also found that Stanley’s state court petitions did not interrupt the prescription period because they did not provide adequate notice of his federal claims or demand monetary damages. Consequently, the Fifth Circuit affirmed the district court’s dismissal of Stanley’s claims as prescribed. View "Stanley v. Morgan" on Justia Law

The case involves a challenge to a Mississippi statute that allows absentee ballots to be received up to five days after the federal Election Day. The plaintiffs, including the Republican National Committee and the Mississippi Republican Party, argued that this state law conflicts with federal statutes that establish a uniform Election Day for federal elections. The plaintiffs sought to enjoin state officials from enforcing the post-election ballot deadline.The United States District Court for the Southern District of Mississippi consolidated two lawsuits and granted summary judgment in favor of the defendants, which included various state election officials. The district court held that Mississippi's statute did not conflict with federal law and thus was not preempted. The plaintiffs appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's judgment. The Fifth Circuit held that the federal Election Day statutes preempt Mississippi's law because federal law mandates that all ballots must be received by Election Day. The court emphasized that the term "election" includes both the casting and receipt of ballots, and that the election is not consummated until all ballots are received. The court also noted that historical practices and other federal statutes support this interpretation. The case was remanded for further proceedings to determine appropriate relief, considering the proximity to upcoming elections. The court also vacated the district court's summary judgment on the plaintiffs' § 1983 claims and remanded for reconsideration. View "Republican National Committee v. Wetzel" on Justia Law

Alex Francois, a Haitian national, left Haiti in 1979 to reunite with his U.S. citizen father. He has lived in New York City, raised six U.S. citizen children, and suffers from severe mental illnesses, including schizophrenia and bipolar disorder. Francois has been hospitalized multiple times for his mental health and has had several encounters with law enforcement, often related to his mental illness. In 2017, he was arrested for trespassing in Texas, found incompetent to stand trial, and subsequently transferred to U.S. Immigration and Customs Enforcement custody. The Department of Homeland Security charged him with removability under 8 U.S.C. § 1182(a)(6)(A)(i).The Immigration Judge (IJ) initially granted Francois withholding of removal, finding that he would likely be persecuted in Haiti due to his mental illness. The IJ based this decision on expert testimony and country conditions evidence, which highlighted the dire conditions and violent treatment of mentally ill individuals in Haitian prisons. The government appealed, and the Board of Immigration Appeals (BIA) remanded the case for further factfinding, questioning whether Francois would be singled out for persecution and whether there was a pattern of persecution against similarly situated individuals.The IJ, on remand, reversed the initial decision, denying Francois's claims for withholding of removal and protection under the Convention Against Torture (CAT). The IJ found that Francois had not proven he would be targeted for persecution in Haiti based on his mental illness. The BIA affirmed this decision, finding no clear error in the IJ's findings. Francois then filed a petition for review with the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit held that the BIA deprived Francois of due process by violating its own regulations, specifically by remanding for further factfinding instead of reviewing the IJ's initial findings for clear error. The court granted Francois's petitions for review, vacated the BIA's orders, and remanded the case for the BIA to review the IJ's initial order under the proper standards of review. View "Francois v. Garland" on Justia Law

In November 2023, X Corp. filed a lawsuit against Media Matters, Inc., Eric Hananoki, and Angelo Carusone, alleging interference with X Corp.'s contracts, business disparagement, and interference with prospective economic advantage. X Corp. claimed that Media Matters manipulated images to portray X Corp. as a platform dominated by neo-Nazism and anti-Semitism, which alienated advertisers, publishers, and users. During discovery, X Corp. requested Media Matters to produce documents identifying its donors and communications with them. Media Matters resisted, citing First Amendment concerns.The United States District Court for the Northern District of Texas initially ordered Media Matters to log documents responsive to X Corp.'s requests as privileged. However, Media Matters did not comply, arguing that the requests overlapped with other discovery requests. The district court then granted X Corp.'s motion to compel production, ruling that Media Matters had waived any First Amendment privilege by not searching for or logging the documents. Media Matters appealed the order and sought a stay pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that it had jurisdiction under the collateral order doctrine, as the discovery order involved important First Amendment issues that were separate from the merits of the case and would be effectively unreviewable on appeal. The court determined that Media Matters was likely to succeed on the merits of its appeal because the discovery requests were not proportional to the needs of the case and posed a significant burden on Media Matters and its donors. Consequently, the court granted Media Matters's motion for a stay pending appeal, staying the district court's order compelling production. View "X Corp v. Media Matters" on Justia Law

Ultra Deep Picasso Pte. Limited (Ultra Deep) is a contractor specializing in undersea vessel operations for marine construction. Dynamic Industries Saudi Arabia Ltd. (Dynamic) subcontracted Ultra Deep for a project related to a contract with Saudi Aramco. Ultra Deep completed work worth over ten million dollars but alleged that Dynamic failed to pay, breaching their agreement. Ultra Deep filed a complaint in the Southern District of Texas, seeking breach of contract damages and a maritime attachment and garnishment of Dynamic’s funds allegedly held by Riyad Bank.The district court granted Ultra Deep an ex parte order for attachment of Dynamic’s assets at Riyad Bank. Dynamic responded with motions to dismiss for lack of personal jurisdiction, improper venue, and to compel arbitration, which were denied. Dynamic and Riyad Bank then moved to vacate the attachment order, arguing that Ultra Deep failed to show Dynamic had property in the Southern District of Texas. The magistrate judge held a hearing and found that Ultra Deep did not present evidence that Dynamic’s property was within the district. The district court adopted the magistrate judge’s recommendation, vacated the attachment order, and dismissed the case with prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that for a valid Rule B attachment, the property must be found within the district. It concluded that a bank account is located where its funds can be withdrawn. Since Ultra Deep failed to show that Dynamic’s property was within the Southern District of Texas, the court affirmed the district court’s decision to vacate the attachment order and dismiss the case. View "Ultra Deep Picasso v. Dynamic Industries Saudi Arabia Ltd." on Justia Law

In 2020, First United Pentecostal Church in DeQuincy, Louisiana, sustained significant damage from Hurricanes Laura and Delta. The church was insured by Church Mutual Insurance Company (CM), which covered several buildings on the property. After the hurricanes, First United submitted a claim to CM, but CM delayed the inspection and payment process. CM eventually made two payments totaling $191,832.28, which the church used for repairs. Dissatisfied with the amount and timing of the payments, First United filed a lawsuit against CM, alleging breach of contract and violations of Louisiana insurance statutes.The United States District Court for the Western District of Louisiana held a bench trial and found in favor of First United. The court concluded that CM had acted in bad faith by failing to make timely payments and awarded First United $1,101,122.87 in unpaid losses, along with statutory penalties, attorney fees, and costs, bringing the total award to $2,073,838.96. The court later amended the judgment to $2,052,335.09 after correcting some errors. CM's motions for a new trial and for judgment as a matter of law were denied, leading to this appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decisions on several points, including the denial of CM's motion to exclude First United's expert, Kermith Sonnier, and the use of Sonnier's estimate to calculate damages. However, the appellate court reversed the district court's imposition of statutory penalties, attorney fees, and costs, finding that CM's actions were not arbitrary, capricious, or without probable cause. The case was remanded for further proceedings consistent with the appellate court's opinion. View "First United v. Church Mutual Insurance" on Justia Law

Justin Henry was observed by New Orleans Police Department officers entering a stolen vehicle in a shopping center parking lot. When approached by police, Henry fled on foot, discarding a firearm in the process. Henry, a convicted felon, was subsequently charged with possession of a firearm by a felon under 18 U.S.C. § 922(g)(1). He pleaded guilty to the charge.The United States District Court for the Eastern District of Louisiana sentenced Henry, applying a four-level enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing a firearm in connection with another felony offense, specifically the possession of a stolen vehicle. The court determined that the firearm facilitated or had the potential to facilitate the possession of the stolen vehicle. This enhancement increased Henry’s sentencing range, resulting in a 100-month prison sentence followed by three years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. Henry argued that the district court erred in applying the sentencing enhancement, contending that the government failed to prove he knew the vehicle was stolen and that the firearm facilitated the possession of the stolen vehicle. The Fifth Circuit found that while the district court could reasonably infer Henry knew the vehicle was stolen, there was insufficient evidence to support the finding that the firearm facilitated the possession of the stolen vehicle. The court noted that mere proximity of the firearm to the stolen vehicle was not enough to apply the enhancement.The Fifth Circuit affirmed Henry’s conviction but vacated his sentence and remanded the case for resentencing, holding that the district court erred in applying the § 2K2.1(b)(6)(B) enhancement without sufficient evidence of facilitation. View "United States v. Henry" on Justia Law

The plaintiffs alleged that the defendants marketed fraudulent franchise opportunities to foreign nationals seeking to invest in the United States to obtain residency visas. The complaint included claims under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state-law claims for fraud, breach of contract, and malpractice. The plaintiffs claimed that the defendants misrepresented the nature of the investment opportunities, leading the plaintiffs to believe they were purchasing franchises that would qualify them for E-2 or EB-5 visas. Instead, they received licenses that did not meet visa requirements, resulting in financial losses and visa application issues.The United States District Court for the Southern District of Texas dismissed the case for failure to state a claim. The court found that the plaintiffs did not adequately allege a cognizable enterprise under RICO and failed to meet the heightened pleading standards for fraud under Federal Rule of Civil Procedure 9(b). The district court also denied the plaintiffs leave to amend their complaint, citing undue delay and the plaintiffs' failure to provide a proposed amended complaint or additional facts that would cure the deficiencies.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs failed to plead a RICO enterprise, as the complaint did not provide sufficient factual detail to support the existence of an association-in-fact enterprise. The court also upheld the dismissal of the fraud and fraudulent inducement claims, finding that the plaintiffs did not meet the particularity requirements of Rule 9(b). Additionally, the court found no abuse of discretion in the district court's denial of leave to amend the complaint and the dismissal of claims against certain defendants for failure to effect timely service of process. View "Crosswell v. Rodriguez" on Justia Law

Dajuan Martin was arrested after being seen riding a stolen scooter in New Orleans. During the police pursuit, he discarded a Glock 26, 9mm semi-automatic handgun, which was later recovered with a magazine containing 16 rounds of ammunition. Martin pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The Presentence Investigation Report (PSR) calculated his offense level at 12, with a criminal history category of III, suggesting a sentencing range of 15 to 21 months. However, the government objected, arguing for a higher base offense level due to the firearm's large capacity magazine.The United States District Court for the Eastern District of Louisiana accepted the government's argument, raising Martin's base offense level to 20, resulting in a new sentencing range of 30 to 37 months. Martin was sentenced to 33 months of imprisonment and 3 years of supervised release. The court also imposed conditions for supervised release, including participation in a drug and alcohol treatment program and submission to searches under certain conditions. However, the written judgment included additional requirements not stated during the oral pronouncement.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martin challenged the district court's application of the Sentencing Guidelines' commentary defining "large capacity magazine" and the discrepancies between the oral pronouncement and the written judgment regarding supervised release conditions. The Fifth Circuit upheld the district court's use of the commentary, finding it consistent with the Guidelines. However, it agreed with Martin that the written judgment improperly broadened the conditions of supervised release.The Fifth Circuit affirmed Martin's sentence in part, vacated it in part, and remanded the case for the district court to amend the written judgment to conform to the oral pronouncement. The court also rejected Martin's constitutional challenge to 18 U.S.C. § 922(g)(1), citing consistent precedent upholding the statute's constitutionality. View "USA v. Martin" on Justia Law

In response to challenges faced during the 2020 election, the Texas Legislature enacted S.B. 1 in 2021, which restricts paid "vote harvesting services." This law aims to protect the privacy of mail-in voters by prohibiting compensated interactions intended to influence votes. Plaintiffs, a coalition of organizations, challenged this provision on vagueness and First Amendment grounds, seeking injunctions against various Texas officials.The United States District Court for the Western District of Texas enjoined the enforcement of the vote harvesting provision of S.B. 1 on September 28, 2024, nearly three years after the law took effect and just three weeks before voting was to begin. The State of Texas then moved to stay the district court's order pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and granted the State's request for a stay. The court emphasized the Supreme Court's guidance in Purcell v. Gonzalez, which advises against altering election laws close to an election due to potential voter confusion and administrative burdens. The court found that the district court's injunction, issued after mail-in ballots had already been distributed, could lead to significant confusion and disruption.The Fifth Circuit held that the plaintiffs' constitutional challenge to S.B. 1 was not "entirely clearcut," failing to meet the criteria that might justify an exception to the Purcell principle. The court noted that the law's provisions were designed to protect voter privacy and security, similar to protections upheld by the Supreme Court for in-person voting. Consequently, the motion to stay the district court's injunction pending appeal was granted. View "La Union del Pueblo Entero v. Abbott" on Justia Law