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

Texas enacted Senate Bill 1, which included several provisions regulating how individuals may assist voters, particularly those who are blind, disabled, or illiterate. The challenged provisions required assistors to disclose personal information, amended the oath assistors must take, and prohibited compensated assistance or paid ballot harvesting. Various organizations with members who require or provide voting assistance argued that these provisions were preempted by Section 208 of the Voting Rights Act, which allows eligible voters to receive assistance from a person of their choice, with certain exceptions.The United States District Court for the Western District of Texas found that at least one plaintiff organization had standing to challenge each provision. The court held that Section 208 preempted all the challenged provisions, reasoning that the federal law did not permit states to impose additional limitations or exceptions beyond those stated in Section 208. As a result, the district court permanently enjoined state officials and certain district attorneys from enforcing the relevant sections of Senate Bill 1.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision. The Fifth Circuit concluded that none of the plaintiff organizations had standing to challenge the disclosure and oath provisions, as their fears of prosecution were speculative and did not constitute an actual or imminent injury. However, the court agreed that two organizations had standing to challenge the compensation provisions, as there was a credible threat of prosecution for their ongoing activities.Addressing the merits, the Fifth Circuit held that Section 208 of the Voting Rights Act does not preempt Texas’s compensation-related restrictions. The court found no clear and manifest congressional intent to preempt such state regulations and rejected the district court’s broader reading of Section 208. The Fifth Circuit reversed the district court’s judgment, vacated the permanent injunction, and remanded the case for further proceedings. View "La Union del Pueblo Entero v. Abbott" on Justia Law

Five individuals were charged in federal court for their roles in a large-scale drug trafficking operation. The scheme involved purchasing marijuana from states where it was legal, such as California and Oregon, and distributing it to twenty-one other states. The operation used drivers to transport marijuana and related products, with cash proceeds handled outside of financial institutions to avoid detection. Law enforcement investigations included surveillance, traffic stops, and searches of residences, warehouses, and storage units, resulting in the seizure of large quantities of marijuana, THC products, cash, and firearms. The lead investigator analyzed cell phone data to estimate the scope of the conspiracy, concluding it involved over 23,000 kilograms of marijuana.The United States District Court for the Eastern District of Texas indicted the five appellants and ten co-defendants on multiple counts, including conspiracy to possess with intent to distribute marijuana, conspiracy to commit money laundering, and other individualized charges. Eight co-defendants pleaded guilty, while the five appellants went to trial. After an eight-day trial, the jury convicted all five of conspiracy to possess with intent to distribute 1,000 kg or more of marijuana and conspiracy to commit money laundering. Roberts was also convicted of continuing criminal enterprise and possession of a firearm in furtherance of a drug trafficking crime. Sentences ranged from 48 to 240 months’ imprisonment, with some counts dismissed or sentences ordered to run concurrently.The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court affirmed the convictions for conspiracy to possess with intent to distribute marijuana and promotional money laundering, but vacated the sentences for certain defendants due to errors in the admission of a summary chart used to estimate drug quantities and clerical errors in the judgments and presentence reports. The court remanded for resentencing under the default penalty provision and correction of clerical errors, while affirming other aspects of the convictions and venue determinations. View "United States v. McGuire" on Justia Law

Ricky Wilson was implicated in an incident at a Waffle House, where he allegedly brandished a green pistol with a drum magazine during a dispute, causing fear in another customer. The victim identified Wilson, his vehicle, and the weapon. A detective, already investigating Wilson for another matter, learned that Wilson’s girlfriend rented an apartment at 212 Central Avenue, where Wilson’s car was later observed. Two weeks after the Waffle House incident, the detective sought and obtained both an arrest warrant for Wilson and a search warrant for the apartment, based on an affidavit that recounted the Waffle House events and stated that items related to the assault were “believed to be located” at the apartment. The search yielded ammunition, marijuana, and a firearm, leading to federal charges against Wilson.The United States District Court for the Eastern District of Louisiana granted Wilson’s motion to suppress the evidence found at the apartment. The court found that the affidavit supporting the search warrant failed to establish a nexus between the Waffle House incident and the apartment, rendering the warrant unsupported by probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply because the affidavit was so lacking in indicia of probable cause that reliance on it was unreasonable. The government appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s suppression of the evidence. The Fifth Circuit held that the affidavit was a “bare-bones” statement, offering no facts connecting the alleged crime to the apartment, and thus failed to establish probable cause. The court further held that the good-faith exception did not apply because the affidavit was so deficient that no reasonable officer could believe it established probable cause. The suppression of the evidence was therefore proper. View "United States v. Wilson" on Justia Law

A Syrian-born naturalized U.S. citizen, together with a business partner, sought to establish a halal beef slaughterhouse in Colombia and solicited investment for the venture. An FBI confidential informant, suspicious of their activities, connected them with an undercover agent posing as a representative of a wealthy investor. The supposed investor agreed to provide $9 million on the condition that at least five percent be sent to Jabhat al-Nusra, a group designated as a foreign terrorist organization by the U.S. State Department. The defendants agreed to this arrangement, took steps to conceal the transfers, and demonstrated knowledge that the funds would support violent acts by the group. The FBI terminated the operation, and the defendant was arrested and charged with conspiracy to murder and maim persons in a foreign country, and conspiracy to provide material support to terrorists and to a designated foreign terrorist organization.The United States District Court for the Western District of Texas presided over the trial, where a jury found the defendant guilty on all counts. The court sentenced him to concurrent terms of 160 months’ imprisonment. The defendant appealed, raising several issues, including the exclusion of his son’s testimony, limitations on cross-examination, sufficiency of the evidence, denial of a combatant-immunity instruction, the jury instruction regarding the terrorist organization’s designation, and the denial of sanctions for an alleged violation of a preservation order by a government witness.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the convictions. The court held that the district court did not abuse its discretion in excluding the son’s testimony or in its evidentiary rulings, found no reversible error in the jury instructions, and determined that the evidence was sufficient to support the convictions. The appellate court also concluded that the district court acted within its discretion in denying sanctions related to the preservation order. View "United States v. Wadi" on Justia Law

A pretrial detainee in the St. Tammany Parish Jail, who has had a prosthetic eye for decades, reported his chronic condition to jail medical staff upon intake. In June 2022, a jail doctor prescribed antibiotics and twice-weekly wound care for an infection in the detainee’s eye socket. Although the detainee was initially scheduled for wound care, he was not taken to his appointments, and his infection worsened over several weeks. The detainee filed multiple grievances, alleging that a deputy failed to escort him to medical care and that a refusal-of-treatment form was falsely completed without his knowledge or signature. After further investigation, jail officials determined that the medical records inaccurately reflected wound care visits, which were actually medication distributions, and ultimately found the detainee’s grievance substantiated.The detainee filed a pro se civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Louisiana, naming jail officials and medical staff as defendants. The district court, through a magistrate judge, granted a motion to dismiss for some defendants and summary judgment for others, entering final judgment against the detainee and dismissing his claims with prejudice. The court denied the detainee’s motions to compel discovery and to amend his complaint, and did not address some discovery requests before entering judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the magistrate judge committed plain error by treating a report and recommendation as a final judgment before it was formally adopted, thereby denying the detainee a full and fair opportunity for discovery. The appellate court reversed the grant of summary judgment for the doctor-defendants, affirmed the dismissal of claims against most jail officials, but found that dismissal should have been without prejudice to allow for amendment. The case was remanded for further proceedings consistent with these holdings. View "James v. Smith" on Justia Law

After being released from a psychiatric hold, Reginald Humbles traveled from Lafayette to New Orleans, Louisiana, with little money and a firearm. When he ran out of gas, he encountered a waste removal truck and, after allegedly receiving a message from God, took the truck at gunpoint from its driver. Humbles then led police on a lengthy chase, which ended after officers deployed spike strips. Upon arrest, a loaded revolver was found in his possession. Humbles, a U.S. Army veteran with a history of mental illness, was indicted for being a felon in possession of a firearm.The United States District Court for the Eastern District of Louisiana accepted Humbles’s guilty plea. During sentencing, the court adopted a presentence report that cross-referenced the robbery Sentencing Guideline, applied an enhancement for reckless endangerment during flight, and included a criminal history point for an uncounseled misdemeanor DUI conviction. The court denied Humbles’s motions for a downward variance and departure based on mental health and military service, and sentenced him to 92 months’ imprisonment. Humbles appealed, challenging the application of the robbery Guideline, the enhancements, the inclusion of his DUI conviction, and the denial of his motions for a lower sentence.The United States Court of Appeals for the Fifth Circuit reviewed the case and found no reversible error. The court held that the district court did not err in cross-referencing the robbery Guideline, as Humbles failed to meet his burden to prove legal insanity at the time of the offense. The court also upheld the enhancements for reckless endangerment and the inclusion of the uncounseled DUI conviction, finding that Humbles knowingly waived his right to counsel. The Fifth Circuit affirmed the district court’s judgment and denied the request to reassign the case to a different judge. View "United States v. Humbles" on Justia Law

An employee at a meatpacking plant in Texas died after contracting COVID-19, allegedly from a coworker who continued working after testing positive. The decedent’s family sued the plant manager, the safety manager, and the coworker in Texas state court, claiming negligence and gross negligence due to unsafe working conditions and inadequate precautions against COVID-19. The complaint alleged that the employer, Tyson Foods, failed to protect employees, and that the managers were responsible for workplace safety. The coworker was accused of coming to work and failing to take precautions after testing positive.The defendants removed the case to the United States District Court for the Eastern District of Texas, arguing that the Texas-based managers were improperly joined to defeat diversity jurisdiction. The district court agreed, dismissed the claims against the managers with prejudice, and denied the plaintiffs’ motion to remand. Tyson Foods was later added as a defendant. The district court then dismissed the claims against Tyson on the grounds that they were preempted by the Poultry Products Inspection Act (PPIA), and dismissed the claims against the coworker for failure to state a claim, finding no individual duty to prevent the spread of disease under Texas law. The court denied leave to amend the complaint as futile and entered final judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s denial of the motion to remand and the dismissal of the coworker, holding that the managers were improperly joined and that Texas law does not impose an individual duty on coworkers to prevent the spread of disease. However, the Fifth Circuit reversed the dismissal of the claims against Tyson, holding that the PPIA does not preempt state law negligence claims based on workplace safety unrelated to food adulteration. The court vacated the denial of leave to amend and remanded for further proceedings. View "Williams v. Wingrove" on Justia Law

The plaintiff, born in Mexico in 1976 to a U.S. citizen father and a Mexican citizen mother, sought recognition of U.S. citizenship based on his father’s physical presence in the United States prior to his birth. His father, born in Texas, had lived in the U.S. for a cumulative sixteen years, including seven years after turning fourteen. The plaintiff’s parents were unmarried at his birth but married in Texas the following year. In 2012, the plaintiff applied to the United States Citizenship & Immigration Services (USCIS) for a certificate of citizenship, submitting various documents to establish his father’s physical presence in the U.S. prior to his birth.USCIS denied the application in 2015, finding insufficient proof of the father’s physical presence. The plaintiff appealed to the Administrative Appeals Office (AAO), which dismissed the appeal in 2018. He then filed a timely motion to reconsider and reopen, submitting additional evidence, but the AAO denied this motion in September 2018. Nearly five years later, in August 2023, the plaintiff filed suit in the United States District Court for the Western District of Texas under 8 U.S.C. § 1503(a), seeking a declaration of citizenship.The district court dismissed the suit for lack of subject-matter jurisdiction, reasoning that the five-year statute of limitations in § 1503(a) was jurisdictional and had expired, starting from the AAO’s dismissal of the appeal rather than the denial of the motion to reopen. On appeal, the United States Court of Appeals for the Fifth Circuit held that the five-year time bar in § 1503(a) is not jurisdictional but a nonjurisdictional claims-processing rule. The court further held that a timely motion to reconsider or reopen extends the time to file suit, and since the plaintiff’s motion was timely, his suit was not time-barred. The Fifth Circuit reversed the district court’s dismissal and remanded for further proceedings. View "Sarabia v. Noem" on Justia Law

The Securities and Exchange Commission (SEC) adopted two rules intended to increase transparency in the securities lending and short sale markets. Securities lending involves temporarily transferring securities from a lender to a borrower for a fee, and is closely tied to short selling, where investors sell securities they do not own, hoping to profit from a price decline. The SEC found both markets to be opaque, making regulatory oversight difficult. To address this, the SEC, under authority from the Dodd-Frank Act, promulgated the Securities Lending Rule (requiring prompt reporting of securities loans) and the Short Sale Rule (mandating monthly aggregate reporting of short sale positions by institutional investment managers).The petitioners, associations representing institutional investment managers, challenged both rules before the United States Court of Appeals for the Fifth Circuit. They argued that the rules were arbitrary and capricious, exceeded the SEC’s statutory authority, conflicted with each other, and that the SEC failed to consider their cumulative economic impact. They also raised procedural objections, including inadequate opportunity for public comment and concerns about the extraterritorial application of the Short Sale Rule. The SEC defended its process and statutory authority, maintaining that the rules addressed distinct regulatory gaps and that its economic analysis was sufficient.The United States Court of Appeals for the Fifth Circuit held that the SEC acted within its statutory authority in adopting both rules and provided adequate opportunity for public comment. The court also found that the SEC reasonably explained its choices regarding reporting systems and that the Short Sale Rule did not have impermissible extraterritorial reach. However, the court concluded that the SEC failed to consider and quantify the cumulative economic impact of the two interrelated rules, as required by the Administrative Procedure Act and the Exchange Act. The court granted the petition for review in part and remanded both rules to the SEC for further proceedings on this issue, while denying the remainder of the petition. View "Natl Assoc Priv Fund Mgr v. SEC" on Justia Law

The case concerns a former CEO of a Texas credit union who was removed from his position after the credit union was placed into conservatorship by state authorities, with the National Credit Union Administration (NCUA) appointed as conservator. The NCUA terminated the CEO, seized property, and allegedly withheld post-termination benefits. The CEO initially sued in Texas state court for those benefits. Before the credit union responded to that suit, the NCUA initiated an administrative enforcement action against him. In response, the CEO filed a federal lawsuit challenging the NCUA’s authority and the constitutionality of the administrative proceedings, raising claims about the removal protections for the administrative law judge, the lack of a jury trial, due process, and the non-delegation doctrine.The United States District Court for the Southern District of Texas dismissed the federal suit for lack of subject matter jurisdiction, finding that 12 U.S.C. § 1786(k)(1) explicitly precludes district court jurisdiction over actions seeking to enjoin or otherwise affect NCUA enforcement proceedings. The district court reasoned that the statutory language was clear and that any challenge to the administrative process must proceed through the statutory review scheme, which provides for review in the courts of appeals after the agency action is final.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The Fifth Circuit held that § 1786(k)(1) explicitly precludes district court jurisdiction over actions seeking to enjoin or otherwise affect NCUA enforcement actions, relying on its recent decision in Burgess v. Whang and Supreme Court precedent interpreting similar statutory language. The court rejected the argument that Congress must specifically reference 28 U.S.C. § 1331 to preclude federal question jurisdiction. The Fifth Circuit affirmed the district court’s dismissal for lack of subject matter jurisdiction. View "Moats v. Natl Crdt Un Admin Bd" on Justia Law