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

Fifty-six Texas emergency-medicine physician groups provided out-of-network emergency care to patients insured by twenty-four Blue Cross Blue Shield-affiliated plans from outside Texas. The physician groups sought reimbursement for their services, relying on assignments of benefits obtained from patients during hospital registration. The Blue Plans paid only part of the billed amounts, and the physician groups pursued appeals through the provider appeals process, but often received generic or no responses. After partial payments and unsuccessful appeals, the physician groups filed suit, alleging underpayment for 290,000 claims. Following a settlement, most claims were dismissed, and the district court selected 182 representative bellwether claims for summary judgment.The United States District Court for the Northern District of Texas granted summary judgment for the Blue Plans on all bellwether claims. The court found that the physician groups lacked standing due to issues with the assignments, such as ambiguous language, lack of written evidence for some claims, and anti-assignment provisions in the underlying plans. The court also held that the physician groups failed to exhaust administrative remedies, as they did not use the member appeals process specified in the plans, and dismissed some claims as time-barred. Final judgment was entered for the Blue Plans, and the physician groups appealed.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. The Fifth Circuit affirmed summary judgment only for claims where no written assignment was produced, finding the physician groups’ evidence insufficient. For the remaining claims, the Fifth Circuit vacated summary judgment and remanded for further proceedings. The court held that ambiguities in assignment language created factual disputes, that assignments of “all rights” could include the right to sue, and that the district court applied the wrong legal standard to estoppel regarding anti-assignment clauses and exhaustion of administrative remedies. The case was remanded for further evidentiary determinations. View "Angelina Emergency Medicine Associates PA v. Blue Cross" on Justia Law

The defendant was charged with multiple counts of sex trafficking and coercion or enticement of prostitution, each count relating to one of four women he managed as a pimp over several years. The women testified that the defendant controlled their earnings, provided necessities, and used physical abuse, threats, and manipulation—including withholding drugs—to force or coerce them into commercial sex acts. Some victims also described having their identification taken and being compelled to travel interstate for sex work. The government’s case included testimony from the victims, law enforcement officers, and documentary evidence such as online advertisements and social media posts.The United States District Court for the Southern District of Texas presided over the trial. During the proceedings, the defense moved for a mistrial or to exclude certain witness testimony, arguing that the government failed to disclose text messages between an investigator and a victim, in violation of Brady v. Maryland and the Jencks Act. The district court denied these motions, allowed the contested testimony, and also denied the defendant’s motions for judgment of acquittal and a new trial. The jury convicted the defendant on all but one count, and the court sentenced him to 480 months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the evidence de novo and found it sufficient to support the convictions. The court held that the missing text messages were not material under Brady or the Jencks Act, as their content was cumulative of other impeachment evidence. The court also found no reversible error in the admission of certain testimony and Instagram posts, concluding that any evidentiary errors were either harmless or not present. The Fifth Circuit affirmed the district court’s judgment in all respects. View "United States v. Lewis" on Justia Law

Carol Rose, a prominent figure in the American Quarter Horse industry, entered into a series of agreements with Lori and Philip Aaron in 2013. The Aarons agreed to purchase a group of Rose’s horses at an auction, lease her Gainesville Ranch with an option to buy, and employ her as a consultant. The relationship quickly soured after the auction, with both sides accusing each other of breaches. Rose locked the Aarons out of the ranch and asserted a stable keeper’s lien for charges exceeding those related to the care of the Aarons’ horses. The Aarons paid the demanded sum and removed their horses. Litigation ensued, including claims by Jay McLaughlin, Rose’s former trainer, for damages related to the value of two fillies.The bankruptcy filings by Rose and her company led to the removal of the ongoing state-court litigation to the United States Bankruptcy Court. After trial, the bankruptcy court ruled in favor of the Aarons on their breach of contract and Texas Theft Liability Act (TTLA) claims, awarding damages and attorneys’ fees, and in favor of McLaughlin on his claim. The United States District Court for the Eastern District of Texas reversed the bankruptcy court’s rulings on the Aarons’ claims and McLaughlin’s claim, vacating the damages and fee awards.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s reversal of the damages award for the Aarons’ breach of contract claim, holding that the Aarons failed to prove damages under any recognized Texas law measure. The Fifth Circuit reversed the district court’s judgment on the TTLA claim, holding that Rose’s threat to retain the Aarons’ horses for more than the lawful amount could constitute coercion under the TTLA, and remanded for further fact finding on intent and causation. The court also reversed and remanded the judgment regarding McLaughlin’s claim, finding his damages testimony legally insufficient. The court left the issue of attorneys’ fees for further proceedings. View "Rose v. Equis Equine" on Justia Law

Felicia Scroggins, a pro se plaintiff, brought claims against the City of Shreveport alleging race and sex discrimination, as well as retaliation, under Title VII. Her allegations included being incorrectly reprimanded for a safety incident, being compelled to undergo a fit-for-duty evaluation, and being disciplined for backing a fire engine into a fence. She also challenged the fairness of the bidding procedures for job assignments, claiming they were applied to her in a discriminatory manner.The United States District Court for the Western District of Louisiana reviewed the case. After Scroggins’s counsel withdrew, the district court granted her several extensions to find new counsel before ruling on the City’s motion for summary judgment. Ultimately, the district court granted summary judgment in favor of the City, finding that Scroggins failed to produce competent summary judgment evidence of pretext for her retaliation claims and that, although she established a prima facie case of discrimination, the City provided legitimate, nondiscriminatory reasons for its actions which she did not rebut.On appeal, the United States Court of Appeals for the Fifth Circuit considered Scroggins’s arguments that the district court erred by granting summary judgment before she could secure new counsel and by inadequately analyzing her claims under the McDonnell Douglas framework. The Fifth Circuit held that Scroggins forfeited her arguments by failing to cite relevant authority and failing to point to evidence in the record to support her claims. The court also found that the district court properly assumed adverse employment actions for purposes of the retaliation claims and correctly applied the McDonnell Douglas test to both discrimination and retaliation claims. The Fifth Circuit affirmed the district court’s grant of summary judgment in favor of the City. View "Scroggins v. City of Shreveport" on Justia Law

The case concerns the former President and CEO of a New Orleans-based commercial bank, who was charged with conspiracy to commit bank fraud, bank fraud, and making false entries in bank records. The evidence at trial showed that he, along with other bank employees and borrowers, engaged in a scheme to misrepresent the creditworthiness of certain borrowers. This allowed the bank to issue loans to insolvent individuals, who then used the proceeds to pay off overdue and overdraft loans, thereby concealing the true financial state of the bank’s loan portfolio. The defendant did not dispute the existence of these loans but argued that he lacked the intent to defraud the bank.After the bank failed in 2017, resulting in significant losses to the FDIC, a federal grand jury indicted the defendant and several co-conspirators. Some co-defendants pleaded guilty, while the defendant proceeded to trial in the United States District Court for the Eastern District of Louisiana. The jury found him guilty on all counts, and he was sentenced to 170 months in prison and ordered to pay substantial restitution. The district court denied his post-trial motions for acquittal, arrest of judgment, and a new trial.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the evidence, the jury instructions, the admission of lay and summary testimony, and the denial of a motion to dismiss based on the government’s handling of privileged emails. The Fifth Circuit held that the evidence was sufficient to support all convictions, the jury instructions were proper and tracked the relevant law, the evidentiary rulings were not an abuse of discretion, and the government’s conduct regarding privileged material did not warrant dismissal. The court affirmed the jury’s verdict in full. View "USA v. Ryan" on Justia Law

In this case, the petitioner was arrested after an incident in which he was accused of firing a gun into a neighbor’s trailer. Law enforcement recovered evidence at the scene and, following his arrest, the petitioner gave a written statement after being advised of his rights. He was indicted on two counts: shooting into a dwelling and possession of a firearm by a convicted felon. Due to a series of administrative errors, judicial conflicts, and continuances, the petitioner remained incarcerated for over three years before trial. During this period, a key defense witness died. The petitioner repeatedly asserted his right to a speedy trial through pro se motions.The Circuit Court of Tishomingo County, Mississippi, applied the four-factor test from Barker v. Wingo to the petitioner’s speedy trial claim. The court found a violation as to the first count (shooting into a dwelling) but not the second (firearm possession), and dismissed only the first count. The petitioner was tried and convicted on the remaining count and sentenced as a habitual offender. The Mississippi Court of Appeals affirmed, holding that the speedy trial right could be analyzed and remedied on a count-by-count basis in a multi-count indictment. The Mississippi Supreme Court and the United States Supreme Court denied further review.The United States Court of Appeals for the Fifth Circuit reviewed the case on habeas corpus. The court held that, under clearly established federal law as determined by the Supreme Court, when a speedy trial violation is found, the only permissible remedy is dismissal of the entire indictment, not just the affected count. The Fifth Circuit concluded that the Mississippi appellate court’s approach was an unreasonable application of federal law. The judgment of the district court was reversed, and the case was remanded with instructions to grant the writ of habeas corpus. View "Berryman v. Huffman" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

A correctional officer employed by the Texas Department of Criminal Justice (TDCJ) for 18 years suffered from diabetes, hypertension, and chronic back pain. She took intermittent leave under TDCJ’s leave-without-pay (LWOP) policy, which allowed up to 180 days of leave in a rolling 12-month period. After returning from leave in 2017, she was reassigned to a less desirable shift without explanation, leading her to file internal grievances and an equal employment opportunity (EEO) complaint. Although her grievance was sustained and she was returned to her preferred shift, subsequent confusion over her LWOP balance resulted in her termination in 2018. She later reapplied for her job but was not rehired, despite recommendations in her favor and a shortage of correctional officers.The United States District Court for the Eastern District of Texas heard her claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. After a jury trial, she prevailed on all counts, receiving $1.8 million in damages, which the district court reduced to $1 million after excluding emotional distress damages per Supreme Court precedent. The court denied the defendants’ motions for judgment as a matter of law and for a new trial, entering final judgment for the plaintiff and awarding attorney’s fees and costs.On appeal, the United States Court of Appeals for the Fifth Circuit held that monetary relief against the executive director under the ADA was barred by sovereign immunity and reversed that portion of the judgment. The court affirmed the jury’s findings on discrimination and retaliation under the Rehabilitation Act against TDCJ, but found the $1 million damages award included amounts that should have been considered front pay, not back pay, and remanded for recalculation. The court also vacated the attorney’s fee award against the executive director and remanded for reconsideration of fees against TDCJ. The judgment was affirmed in part, reversed in part, vacated, and remanded. View "Harmon v. Collier" on Justia Law

An advanced practice registered nurse in Texas, who maintained an active nursing license and a Prescriptive Authority Number, did not have a current prescriptive-authority agreement with a physician, as required by Texas law to prescribe drugs. She was not accused of any misconduct but was attending an educational program to transition careers. Because she lacked a prescriptive-authority agreement, the Drug Enforcement Administration (DEA) initiated proceedings to revoke her federal Certificate of Registration, which allows her to handle controlled substances.An administrative law judge within the DEA recommended revocation, finding that she was “without state authority to handle controlled substances.” The Administrator of the DEA adopted this recommendation and revoked her registration. The nurse then petitioned for review directly to the United States Court of Appeals for the Fifth Circuit, as permitted by statute.The United States Court of Appeals for the Fifth Circuit reviewed the DEA’s action and concluded that the agency exceeded its statutory authority under 21 U.S.C. § 824(a)(3). The court held that the statute requires both the loss of a state license or registration and the lack of state authorization to handle controlled substances before the DEA may revoke a registration. Because the nurse still held all relevant state licenses and registrations, the court determined that the DEA lacked authority to revoke her registration solely due to the absence of a prescriptive-authority agreement. The court granted the petition for review, vacated the DEA’s revocation order, and remanded the case to the agency for further proceedings consistent with its opinion. View "DeWitt v. Drug Enforcement Administration" on Justia Law

An attorney who represented a client in a high-profile employment discrimination case against Louisiana State University (LSU) officials later brought suit against two attorneys and their law firm who had served as outside counsel to LSU. The plaintiff alleged that these attorneys engaged in misconduct during a Title IX investigation and, during subsequent state court litigation, made defamatory statements about him, including accusations of fabricating evidence. The state court had previously imposed significant monetary sanctions against the plaintiff and his client, citing, among other things, the plaintiff’s alleged fabrication of evidence and abusive litigation tactics.After the state court proceedings, the plaintiff filed a new lawsuit in the United States District Court for the Middle District of Louisiana, asserting claims for defamation, negligent infliction of emotional distress, intentional infliction of emotional distress, and civil conspiracy under Louisiana law. The district court dismissed all claims with prejudice. It found the defamation claim barred by the Rooker–Feldman doctrine, which limits federal review of state court judgments, and determined that the intentional infliction of emotional distress claim was inadequately pleaded. The court also dismissed the conspiracy claim for lack of an underlying tort and denied leave to amend the complaint.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the Rooker–Feldman doctrine did not bar the defamation claim because the plaintiff’s alleged injury arose from the defendants’ conduct, not from the state court judgment itself. The court vacated the dismissal of the defamation and conspiracy claims and remanded for further proceedings. However, it affirmed the dismissal of the intentional infliction of emotional distress claim, finding the alleged conduct did not meet the required legal standard. The court also vacated the denial of leave to amend the complaint. View "English v. Crochet" on Justia Law