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

Kehinde Adeyemi Elebute challenged the foreclosure sale of his property in bankruptcy court but was unsuccessful. Years later, he attempted to challenge the foreclosure again in state court. To prevent duplicative litigation, the suit was removed to the bankruptcy court, which reopened and subsequently dismissed Elebute’s case for want of prosecution after he failed to appear at a hearing.The United States District Court for the Southern District of Texas dismissed Elebute’s challenge to the reopening and affirmed the bankruptcy court’s dismissal. Elebute then appealed both rulings.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that it lacked jurisdiction to review the bankruptcy court’s order reopening the proceedings, as it was a non-final, interlocutory order. The court agreed with the defendants, Village Capital & Investment, L.L.C., and Michael Weems, that the reopening order was only a preliminary step and did not resolve substantive issues. Therefore, the court dismissed this portion of Elebute’s appeal.Regarding the dismissal for lack of prosecution, the court found that the bankruptcy court had jurisdiction over Elebute’s claims. The court noted that the bankruptcy court’s jurisdiction extends to all civil proceedings related to bankruptcy cases. Since Elebute’s state action challenged Village Capital’s interest in the property central to the earlier bankruptcy case, the actions were related. Consequently, the bankruptcy court had jurisdiction to dismiss the adversary proceeding.The Fifth Circuit dismissed Elebute’s challenge to the reopening order for lack of jurisdiction and affirmed the district court’s judgment in all other respects. The defendants’ amended motion to dismiss a portion of Elebute’s appeal was denied as moot. View "Elebute v. Village Capital" on Justia Law

In 1992, six-year-old Angelo Garcia, Jr. was kidnapped and murdered after two masked intruders broke into the apartment of his parents, Arturo Rodriguez and Diana Garcia. Diana was sexually assaulted during the incident. The case went cold until 2007 when DNA evidence linked Obel Cruz-Garcia to the crime. Cruz-Garcia was convicted of capital murder in 2013 and sentenced to death. His conviction and sentence were affirmed on direct appeal, and his state habeas applications were denied.The United States District Court for the Southern District of Texas denied Cruz-Garcia’s federal habeas petition. Cruz-Garcia then sought a certificate of appealability (COA) from the United States Court of Appeals for the Fifth Circuit, raising three issues: jurors’ use of the Bible during deliberations, ineffective assistance of counsel, and the exclusion of DNA evidence affecting his ability to present a complete defense.The Fifth Circuit denied the COA. The court found that the jurors’ reference to the Bible did not constitute an improper external influence, as it did not relate directly to the facts of the case. The court also determined that Cruz-Garcia’s ineffective assistance of counsel claims lacked merit, as his counsel’s performance was within the wide range of professionally competent assistance. Lastly, the court held that the trial court’s exclusion of certain DNA evidence did not violate Cruz-Garcia’s right to present a complete defense, as he was allowed to introduce other evidence regarding the DNA’s reliability.The Fifth Circuit concluded that Cruz-Garcia failed to make a substantial showing of the denial of a constitutional right and denied his motion for a COA. View "Cruz-Garcia v. Guerrero" on Justia Law

George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law

Joseph Mirelez submitted a claim under his homeowner’s insurance policy with State Farm Lloyds for wind damage to his property. Disputes arose regarding the amount of loss and repair costs, leading Mirelez to invoke the appraisal process. In January 2023, an agreement on the loss amount was reached, but coverage issues persisted. Mirelez filed a lawsuit in state court in May 2023, alleging breach of contract, violations of the Texas Prompt Payment of Claims Act (TPPCA), various bad faith claims under the Texas Insurance Code, and breach of the duty of good faith and fair dealing. State Farm removed the case to federal court, citing diversity jurisdiction, and subsequently paid the appraisal award amount, minus the deductible and prior payments, plus interest.The United States District Court for the Southern District of Texas granted summary judgment in favor of State Farm on all claims. Mirelez conceded that summary judgment was appropriate for his breach of contract and TPPCA claims but contested the dismissal of his statutory and common law bad faith claims. The district court concluded that State Farm had paid all benefits owed under the policy and that Mirelez was not entitled to any additional damages under the Texas Insurance Code.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that under Texas Supreme Court precedent, specifically Ortiz v. State Farm Lloyds, payment of an appraisal award forecloses an insurer’s liability for breach of contract and bad faith claims unless the insured suffered an independent injury. Since Mirelez only sought policy benefits that had already been paid and did not allege any independent injury, his extracontractual bad faith claims were barred. View "Mirelez v. State Farm" on Justia Law

A&T Maritime Logistics, Inc. had an insurance contract with RLI Insurance Company and a bareboat charter agreement with Alexis Marine, L.L.C. While operating the M/V Uncle John, a vessel owned by Alexis Marine, A&T Maritime caused the ship to allide with an embankment. Believing the damage to be minimal, A&T Maritime did not take immediate action. After a lawsuit was filed, RLI was notified of the claim. A&T Maritime and Alexis Marine sought defense and indemnification from RLI, which denied coverage under the insurance contract. The district court upheld RLI's denial of coverage on summary judgment, finding that RLI was prejudiced by the delayed notice.The United States District Court for the Eastern District of Louisiana initially denied A&T Maritime's and Alexis Marine's motions for partial summary judgment seeking reimbursement for defense costs, noting that the policy did not include a duty to defend. The Champagnes, who had purchased the damaged property, settled their claims for $200,000, funded solely by Alexis Marine. RLI then moved for summary judgment, arguing that the Uncle John was not covered under the policy. The district court disagreed but granted partial summary judgment to RLI, holding that the prompt notice requirements were breached and RLI was prejudiced.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The court held that RLI was actually prejudiced by the delayed notice from both A&T Maritime and Alexis Marine, as the damage worsened over time and the opportunity to settle for a lower amount was lost. Consequently, the denial of coverage for both A&T Maritime and Alexis Marine was appropriate. The court also concluded that RLI had no duty to reimburse defense costs, as indemnification depended on coverage, which was voided due to the breach of the prompt notice requirement. View "A&T Maritime Logistics v. RLI Insurance Co." on Justia Law

Three states challenged an executive order issued by President Joseph R. Biden, which mandated that federal contractors pay their workers a minimum hourly wage of $15. The states argued that the President exceeded his authority under the Federal Property and Administrative Services Act (FPASA) and that the order violated the Administrative Procedure Act (APA) and the nondelegation doctrine. The district court for the Southern District of Texas agreed with the states, finding that the FPASA did not grant the President broad authority to set minimum wages for federal contractors and that the executive order was a major question beyond the President's authority. The court permanently enjoined the executive order.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court examined whether the executive order was a permissible exercise of the President's authority under the FPASA. The court found that the FPASA's language was clear and unambiguous, granting the President broad authority to prescribe policies necessary to carry out the Act's provisions, as long as those policies were consistent with the Act. The court determined that the executive order met these requirements, as it aimed to promote economy and efficiency in federal procurement by ensuring contractors paid their workers adequately.The Fifth Circuit also addressed the application of the major questions doctrine, concluding that it did not apply in this case because the FPASA's text was clear and unambiguous. The court noted that the President's exercise of proprietary authority in managing federal contracts did not raise a major question requiring clear congressional authorization. Consequently, the court reversed the district court's permanent injunction and remanded the case for further proceedings consistent with its opinion. View "State of Texas v. Trump" on Justia Law

Pie Development, L.L.C. was formed to develop an application to streamline the process of purchasing workers compensation insurance. The company alleged that Dax Craig, a consultant, stole the idea and shared it with John Swigart. Craig and Swigart then used the idea to create Pie Insurance Holdings, Inc. and other affiliated entities, generating significant profits. Pie Development sued Craig, Swigart, Pie Insurance Holdings, and Pie Insurance Services, alleging misappropriation of trade secrets under the Mississippi Uniform Trade Secrets Act (MUTSA) and the federal Defend Trade Secrets Act (DTSA), among other claims.The United States District Court for the Southern District of Mississippi dismissed the complaint for failing to provide sufficient detail on each claim, but allowed Pie Development to amend its complaint within thirty days. Pie Development chose not to amend and instead appealed. The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision, noting that Pie Development did not sufficiently plead that it took reasonable measures to protect its business plan's secrecy.While the appeal was pending, Pie Development filed a new lawsuit against additional defendants, including Pie Carrier Holdings, Gallatin Point Capital, Sirius Point Ltd., and Pie Casualty Insurance Company, and later added the original defendants. The district court dismissed the new claims, citing res judicata, as the claims were identical to those in the first lawsuit. Pie Development appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that res judicata applied because the prior action was concluded by a final judgment on the merits when Pie Development chose to appeal rather than amend its complaint. The court also found that Pie Development failed to state a claim against Gallatin and Sirius, as the complaint did not plausibly allege that they knew or should have known about the misappropriation of trade secrets. View "Pie Development v. Pie Carr Holdings" on Justia Law

The case involves a challenge to the constitutionality of 18 U.S.C. §§ 922(b)(1) and (c)(1), which prohibit Federal Firearms Licensees (FFLs) from selling handguns to individuals aged eighteen to twenty. The plaintiffs, including individuals in this age group and several nonprofit organizations, argue that these provisions infringe on their Second Amendment rights and deny them equal protection under the Fifth Amendment.The United States District Court for the Western District of Louisiana found that the plaintiffs had standing but dismissed the case under Rule 12(b)(6). The district court assumed that the Second Amendment's plain text covered the purchase of firearms by eighteen-to-twenty-year-olds but concluded that the prohibition was consistent with the nation's historical tradition of firearm regulation, relying on the framework established by the Supreme Court in New York Rifle & Pistol Ass’n, Inc. v. Bruen.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the Second Amendment does cover the right of eighteen-to-twenty-year-olds to purchase firearms. The court found that the historical evidence presented by the government, including 19th-century laws, was insufficient to establish a tradition of restricting firearm rights for this age group in a manner similar to the contemporary federal handgun purchase ban. The court emphasized that the Second Amendment's protections extend to all law-abiding, adult citizens, including those aged eighteen to twenty.The Fifth Circuit held that 18 U.S.C. §§ 922(b)(1) and (c)(1) and their attendant regulations are unconstitutional as they are inconsistent with the nation's historical tradition of firearm regulation. The court reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives" on Justia Law

In 2014, McDonnel Group, L.L.C. served as the general contractor for the renovation of Jung, L.L.C.'s property. In 2015, McDonnel obtained insurance from Starr Surplus Lines Insurance Company and Lexington Insurance Company. In 2017, the project experienced significant water damage, leading McDonnel to file a claim for $3,226,164.30. The dispute arose over the flood deductible amount, with McDonnel asserting it was $500,000, while the insurers claimed it was $3,443,475, resulting in no payout under the policy.The United States District Court for the Eastern District of Louisiana granted summary judgment in favor of the insurers, determining that the policy language regarding the flood deductible was clear and unambiguous. The plaintiffs appealed, and the United States Court of Appeals for the Fifth Circuit found the policy language ambiguous and remanded the case for further proceedings to consider extrinsic evidence and the presumption in favor of coverage.Upon remand, the district court reviewed supplemental briefings and extrinsic evidence, ultimately finding in favor of the insurers. The court concluded that the extrinsic evidence resolved the ambiguity, showing that the industry standard interpretation of "VARTOL" (value-at-risk-at-time-of-loss) supported the insurers' deductible calculation. The plaintiffs appealed again.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The appellate court agreed that the extrinsic evidence provided by the insurers, including industry standards and expert testimony, resolved the ambiguity in the policy language. The court also held that the district court did not err in not applying the presumption in favor of coverage, as the ambiguity had been resolved through extrinsic evidence. View "McDonnel Group v. Starr Surplus Lines" on Justia Law

Ignacia Carmona, representing herself and the estate of Veronica Carmona, filed a lawsuit against the City of Brownsville and several officers, claiming that the officers failed to provide necessary medical care to Veronica Carmona, who died while in pretrial detention. Veronica had been involved in multiple car accidents on the same night and exhibited visible injuries. Despite this, the officers did not seek medical attention for her, and she was later found dead in her cell due to internal bleeding from liver lacerations.The United States District Court for the Southern District of Texas dismissed the claims against the officers, granting them qualified immunity. The court concluded that the complaint did not plausibly allege that the officers had subjective knowledge of a substantial risk of serious harm to Veronica Carmona. The court found that the officers' failure to seek medical care did not amount to deliberate indifference because the injuries were not visibly apparent, and there were no complaints from Carmona that revealed the full extent of her injuries.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the plaintiff failed to plausibly allege that the officers were subjectively aware of the risk of internal bleeding. The court emphasized that actual knowledge of the risk is required for liability, and mere negligence or the fact that the officers should have known about the risk is insufficient. As a result, the officers were entitled to qualified immunity, and the dismissal of the deliberate-indifference claims was upheld. View "Carmona v. Olvera" on Justia Law