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

In this case, Trey Wooley filed a state court action against N&W Marine Towing (N&W) and others based on injuries he suffered while serving as a deckhand on the Mississippi River. The United States Court of Appeals for the Fifth Circuit held that Wooley had improperly joined N&W in the state court action in violation of a district court's stay order and the Limitation of Liability Act of 1851, which effectively ceased all claims and proceedings against N&W outside of a federal limitation action that N&W had previously filed. Therefore, N&W was dismissed as a defendant in the state court action. The court further held that, after dismissing N&W, there were no live claims remaining in the state court action because Wooley had previously settled his claims against the other defendants. Consequently, the court severed Wooley's state court action from the limitation action and dismissed it without prejudice. The court retained jurisdiction over the limitation action but stayed it to allow Wooley to pursue any viable claims against N&W in state court. The court concluded that the district court properly denied Wooley's motion to remand, as it had diversity jurisdiction over the case once N&W was dismissed. View "Wooley v. N&W Marine Towing" on Justia Law

The case revolves around the death of Rhonda Newsome, a pretrial detainee, who died in Anderson County Jail due to complications from Addison’s disease. Her family filed a lawsuit under 42 U.S.C. § 1983 against Anderson County, Sheriff Greg Taylor, Dr. Adam Corley, Nurse Timothy Green, and several jailers, alleging that the defendants violated Newsome’s Fourteenth Amendment rights as a pretrial detainee by failing to treat her chronic illness, resulting in her preventable death. The district court granted summary judgment for all Defendants and dismissed Plaintiffs’ lawsuit with prejudice. Upon review, the United States Court of Appeals for the Fifth Circuit found that Plaintiffs have established genuine disputes of material fact regarding whether several defendants violated Newsome’s clearly established constitutional rights. Thus, the court reversed the district court’s grant of summary judgment for several defendants, but affirmed the district court’s grant of summary judgment for others. The district court’s denial of Plaintiffs’ motion for leave to file a third amended complaint was also vacated, and instructions were given to grant Plaintiffs leave to amend their pleadings to include additional supervisory and municipal liability claims. Finally, the district court’s denial of Plaintiffs’ motion for sanctions was affirmed. View "Ford v. Anderson County" on Justia Law

In 2015, Brian McNeal was found guilty of possessing cocaine and drug paraphernalia in Louisiana. He was given a five-year suspended sentence with five years of probation. In 2017, McNeal was arrested for violating probation and subsequently sentenced to serve 90 days at an in-patient substance abuse program. The Louisiana Department of Public Safety and Corrections (DPSC) determined McNeal's release date was to be November 1, 2017. However, McNeal was not released until December 12, 2017, 41 days after his proper release date. In 2018, McNeal sued James LeBlanc, the DPSC Secretary, in his individual capacity for wrongfully detaining him after his sentence expired. LeBlanc filed a motion to dismiss on the grounds of qualified immunity, which the district court denied. LeBlanc then appealed this decision to the United States Court of Appeals for the Fifth Circuit.The Court of Appeals affirmed the district court's decision, finding that McNeal's claims were not barred by Heck v. Humphrey, 512 U.S. 477 (1994), a case that limits certain legal claims if they would imply the invalidity of a conviction or sentence. The court reasoned that McNeal did not challenge his conviction or attendant sentence, but rather the 41 days he was imprisoned beyond his release date. Therefore, Heck did not apply.The court also rejected LeBlanc's argument that he was entitled to qualified immunity, a legal doctrine that shields government officials from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights. The court determined that McNeal had sufficiently alleged that LeBlanc was deliberately indifferent to a pattern of overdetention in the DPSC. Furthermore, the court found that the right to a timely release from prison was clearly established at the time of McNeal's overdetention. Consequently, the court concluded that LeBlanc was not entitled to qualified immunity in this case. View "McNeal v. LeBlanc" on Justia Law

The United States Court of Appeals for the Fifth Circuit denied the NAACP and other plaintiffs' emergency motions for an injunction to halt the implementation of Mississippi's House Bill 1020 (H.B. 1020). This law created a new lower court for Jackson’s Capitol Complex Improvement District (CCID), which allegedly has a disproportionate share of Jackson's white residents. The judge and prosecutors for this new court would be appointed by the Chief Justice of the Mississippi Supreme Court and the Mississippi Attorney General, respectively, rather than by locally elected officials, as is typical for other municipal courts in Mississippi. The plaintiffs claimed that this appointment process violated their Fourteenth Amendment rights to equal protection of the law.However, the court found that plaintiffs lacked standing because they failed to demonstrate a legally protected interest in the accountability of the CCID court to locally elected officials, or that H.B. 1020 would affect their voting rights by diluting the local government's control over the enforcement of its laws within the CCID's borders. The court also rejected the plaintiffs' claim of stigmatic harm, finding that they did not allege discriminatory treatment as required. Finally, the court found no merit in the argument that benefits from the CCID court would primarily go to a disproportionately white population, as the plaintiffs failed to show how H.B. 1020 would erect a barrier making it more difficult for members of one group to obtain benefits than another. View "NAACP v. Tindell" on Justia Law

In a case before the United States Court of Appeals for the Fifth Circuit, Jessica Banks sued the Texas Department of Family and Protective Services (DFPS) for removing her four-year-old son R.B. from her custody without parental consent or a court order, alleging violations of the Fourth and Fourteenth Amendments. The district court denied DFPS's motion for summary judgment, finding that its employees were not entitled to qualified immunity as they had violated clearly established law.DFPS appealed the decision, but the appellate court affirmed in part and reversed in part. The court found that the removal of R.B. violated the constitutional rights of both the child and Banks, as there were no exigent circumstances that justified a warrantless removal from his mother. The court emphasized that the mere possibility of danger in the future was not enough to constitute exigent circumstances. The court also held that the law was clearly established that removing a child from their home without consent, a court order, or exigent circumstances was a constitutional violation.However, the court reversed the district court's denial of qualified immunity for Linda Juarez, an Investigation Supervisor at DFPS. The court ruled that Juarez was not the ultimate decision-maker and was not actively involved in the decision to remove R.B., thereby entitling her to qualified immunity. View "Banks v. Herbrich" on Justia Law

In this case heard in the United States Court of Appeals for the Fifth Circuit, Marta Alicia Mejia-Alvarenga, a citizen of El Salvador, sought to challenge the denial of her application for asylum by the Board of Immigration Appeals (BIA). Mejia-Alvarenga was detained when trying to cross the Rio Grande into the United States and was subsequently charged with removability due to her lack of valid documentation. She filed an application for statutory withholding of removal and protection under the Convention Against Torture, later amending her application to seek asylum, based on threats she received from a man named Rigoberto Nelson and others associated with him.The immigration judge denied Mejia-Alvarenga’s application and ordered her removal to El Salvador. Despite finding Mejia-Alvarenga a credible witness and acknowledging she had suffered previous harm amounting to persecution, the immigration judge ruled she had not been harmed due to political opinion or membership in a particular social group. The judge also concluded that Mejia-Alvarenga did not demonstrate a well-founded fear of future persecution because she did not show that the government would be unable or unwilling to control a future persecutor.The Court of Appeals denied Mejia-Alvarenga's petition in part and dismissed it in part due to lack of jurisdiction. It ruled that the BIA did not err in concluding that Mejia-Alvarenga failed to establish that the Salvadoran government was unable or unwilling to protect her from private persecutors. The court also rejected Mejia-Alvarenga’s claim that the BIA violated its regulatory obligation to be impartial and her argument that the BIA violated her due process rights by allowing a single BIA member to render its decision. Lastly, the court dismissed Mejia-Alvarenga's claim that the BIA committed an abuse of discretion by not referring her case to a three-member BIA panel, ruling it lacked jurisdiction over this claim. View "Mejia-Alvarenga v. Garland" on Justia Law

In this case, the United States Court of Appeals for the Fifth Circuit considered an appeal by Jose Guadalupe Diaz-Diaz and Martin Perez-Marrufo, two members of the Barrio Azteca gang, who were convicted for their involvement in the murders of three people in Ciudad Juarez, Mexico in 2011. The defendants separately appealed their convictions and sentences, specifically questioning whether sufficient evidence existed to support their convictions for conspiracy to commit murder in a foreign country under 18 U.S.C. § 956(a)(1). Diaz also challenged his aiding-and-abetting convictions and his three consecutive life sentences for his convictions under 18 U.S.C. § 924(c) and (j). Perez-Marrufo also challenged an obstruction of justice enhancement imposed at sentencing.The court held that sufficient evidence existed to support the defendants' convictions for conspiracy to commit murder in a foreign country. The court also affirmed the obstruction of justice sentencing enhancement in Perez-Marrufo's case and the sufficiency of the evidence to support Diaz's convictions for aiding and abetting in Salcido's murder. However, the court held that the district court erred in imposing mandatory consecutive life sentences for Diaz's three section 924(j) convictions and remanded the case for resentencing on these counts. View "USA v. Diaz Diaz" on Justia Law

In the case of Wages and White Lion Investments, L.L.C., doing business as Triton Distribution; Vapetasia, L.L.C., versus the Food & Drug Administration, the court found that the FDA acted arbitrarily and capriciously in its denial of Premarket Tobacco Product Applications (PMTAs) for flavored e-cigarette products.The petitioners, Triton Distribution and Vapetasia, are manufacturers of flavored e-cigarette liquids. They filed PMTAs for their products, as required by the Family Smoking Prevention and Tobacco Control Act, which prohibits the sale of any “new tobacco product” without authorization from the FDA. The FDA, after issuing detailed guidance on the information it required for approval of e-cigarette products, subsequently denied all flavored e-cigarette applications, including those of the petitioners, on the grounds that they failed to predict new testing requirements imposed by the FDA without notice.The court found that the FDA had failed to provide the manufacturers with fair notice of the rules, had not acknowledged or explained its change in position, and had ignored the reasonable and serious reliance interests that manufacturers had in the pre-denial guidance. Furthermore, the FDA attempted to cover up its mistakes with post hoc justifications at oral argument.As a result, the court granted the petitions for review, set aside the FDA's marketing denial orders, and remanded the matters to the FDA. The court rejected FDA's argument that even if it arbitrarily and capriciously denied petitioners’ applications, that error was harmless, stating that the harmless error doctrine is narrow and does not apply to discretionary administrative decisions. The court also rejected FDA's contention that it gave manufacturers fair notice of their obligations to perform long-term scientific studies in its pre-denial guidance documents. View "Wages and White Lion Invest v. FDA" on Justia Law

In a case involving the State of Texas, the American Association of Pro-Life Obstetricians & Gynecologists, and the Christian Medical & Dental Associations as plaintiffs, and the United States Department of Health and Human Services (HHS), its Secretary Xavier Becerra, the Centers for Medicare and Medicaid Services (CMS), and other officials as defendants, the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The plaintiffs challenged HHS's guidance on the Emergency Medical Treatment and Active Labor Act (EMTALA), which they alleged mandated providers to perform elective abortions beyond HHS's authority and contrary to state law. The plaintiffs sought to enjoin the enforcement of this guidance. The district court granted the injunction within Texas or against any member of a plaintiff organization, and HHS appealed.The Court of Appeals held that the HHS guidance constituted a final agency action as it binds HHS to a particular legal position and has clear legal consequences should a physician or hospital violate it. The court found that HHS's guidance exceeds the statutory language of EMTALA, which does not mandate any specific type of medical treatment, let alone abortion care. The court also held that HHS was required to subject the guidance to notice and comment as it "establishes or changes a substantive legal standard." The court affirmed the injunction, finding it not overbroad, but rather tailored based on the parties, issues, and evidence before it. View "Texas v. Becerra" on Justia Law

In an appeal before the United States Court of Appeals for the Fifth Circuit, two defendants, Robert Brumfield and Jeremy Esteves, convicted for their roles in a 2013 armed truck robbery in New Orleans, challenged the district court's denial of their motion for a new trial. This motion was based on their claim that the Government had suppressed evidence related to the credibility of two witnesses, which they argued violated the rules established in Brady v. Maryland and Giglio v. United States. In addition, Brumfield separately claimed that the Government failed to correct false testimony and also appealed his sentence.The Court found that the new evidence was not material in Brumfield's case, his claim of false testimony was without merit, and his sentence was both procedurally and substantively reasonable. However, the Court concluded that the new evidence was material as to Esteves, and thus his Brady claim required further consideration by the district court. Consequently, the Court affirmed in part, reversed in part and remanded the case to the district court for further consideration of Esteves’s Brady claim. View "USA v. Brumfield" on Justia Law