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

This case involves Delta Charter Group, Inc. (Delta), a public charter school operating within Concordia Parish in Louisiana. The case has its roots in a 1965 lawsuit against the Concordia Parish School Board for operating segregated schools in violation of the Fourteenth Amendment. The district court approved a desegregation plan, but the Board has yet to achieve unitary status, and Delta, which had intervened in the ongoing desegregation case, was required by a 2013 consent order to comply with the Board's desegregation decree. A second consent order in 2018 outlined a race-based enrollment process for Delta, giving the highest enrollment preference to black students.Four years later, Delta moved to discontinue the race-based enrollment process, arguing that it was unconstitutional. The district court declined to modify the order under Federal Rule of Civil Procedure 60(b)(5), which allows courts to modify or dissolve a consent decree if applying it prospectively is no longer equitable. Delta failed to show a significant change in factual conditions or in law that would justify modification. The United States Court of Appeals for the Fifth Circuit affirmed the judgment of the district court, stating that Delta had forfeited any argument that the district court had abused its discretion by failing to adequately brief the argument on appeal. The court did not offer any opinion on the underlying constitutional merits, as Delta had forfeited any available argument that the district court should have applied Rule 54(b) and that it had abused its discretion in denying relief under Rule 60(b)(5). View "Delta Charter v. Sch Bd Concordia Prsh" on Justia Law

A group of plaintiffs, who are voters in Travis County, Texas, filed a lawsuit against county officials alleging violations in the conduct of the November 2020 general election. Specifically, they claimed that the defendants used an uncertified electronic voting system for the election, thereby violating several state and federal laws. They sought injunctive and declaratory relief to prohibit electronic voting in Travis County, require paper ballots, and unseal various records related to the 2020 general election. The defendants removed the case to federal court and moved to dismiss the lawsuit, arguing that the plaintiffs lacked standing. The district court agreed and dismissed the case without prejudice. The decision was appealed to the United States Court of Appeals for the Fifth Circuit.In its decision, the Fifth Circuit agreed with the district court that the plaintiffs lacked standing to sue under Article III of the U.S. Constitution, which requires a plaintiff to establish that they have suffered a concrete and particularized injury that is likely caused by the defendant and would likely be redressed by judicial relief. The plaintiffs alleged two injuries: their votes were invalidated and not counted, and their personal information was unlawfully disclosed. The court found that neither injury was sufficient for Article III standing.However, the Fifth Circuit disagreed with the district court's dismissal of the case. Instead, it ruled that the proper course of action, when a federal court lacks subject matter jurisdiction due to a lack of standing, is to remand the case to state court rather than dismissing it. Accordingly, the Fifth Circuit vacated the district court's order and remanded the case with instructions to send it back to state court. View "Lutostanski v. Brown" on Justia Law

The case involves James Pierre, the sole doctor at a Houston pill mill, who was convicted of multiple federal drug crimes. He was charged with seven counts of unlawfully distributing and dispensing controlled substances and one count of conspiring to do the same. Pierre's defense argued that he had been deceived by the clinic's employees and only provided medicine for people he believed were in pain. However, the jury did not believe him and he was convicted on all counts.Pierre appealed his conviction on two grounds: that the district court erred in admitting improper profiling evidence and in instructing the jury. The United States Court of Appeals for the Fifth Circuit, however, found no reversible error and affirmed the conviction. The court held that the testimony about the mill operations was not profiling evidence, as it helped the jury understand the evidence. The court also held that any error in the jury instructions did not affect Pierre's substantial rights, as there was overwhelming evidence to prove that Pierre knew the prescriptions he was writing were medically unauthorized. View "USA v. Pierre" on Justia Law

In this case brought before the United States Court of Appeals for the Fifth Circuit, the plaintiffs were appealing the wording of a district court's declaratory judgment which held certain voter-registration provisions in the Houston City Charter unconstitutional. The plaintiffs were up against the City of Houston and two officials, Anna Russell and Pat J. Daniel, who were acting in their official capacities as City Secretaries.The court, however, found that there was no case or controversy as both parties had agreed from the start that the voter registration provisions were unconstitutional, and the city confirmed that it could not and would not enforce these provisions. The court cited precedent confirming that where there is no adversity between the parties on a constitutional question, there is no Article III case or controversy.Therefore, the court vacated the district court's judgment and remanded the case with instructions to dismiss the suit without prejudice, stating that such faux disputes do not belong in federal court. This dismissal allows for the possibility of the case being refiled in a competent jurisdiction in the future if necessary. View "Pool v. City of Houston" on Justia Law

Derrick Durrell Jones, a convicted felon, pleaded guilty to possession of a firearm and appealed his conviction to the United States Court of Appeals for the Fifth Circuit. Jones argued that the law under which he was convicted, 18 U.S.C. § 922(g)(1), was unconstitutional because it violated the Commerce Clause and the Second Amendment. Addressing the Commerce Clause argument, the court stated that their circuit precedent has consistently upheld the constitutionality of § 922(g)(1), and that Jones had not presented any Supreme Court decisions that had expressly overruled this.In response to the Second Amendment argument, the court noted that Jones' challenge came in light of a new test for assessing the constitutionality of a statute under the Second Amendment as set forth by the Supreme Court in New York State Rifle & Pistol Ass’n, Inc. v. Bruen. However, the court pointed out that it had previously held that § 922(g)(1) did not violate the Second Amendment, and a concurring opinion in Bruen had stated that the decision should not cast doubt on prohibitions on the possession of firearms by felons. The court also observed that there was no binding precedent holding that § 922(g)(1) was unconstitutional, and that two other federal circuits have reached conflicting conclusions on the issue.Given these considerations, the court concluded that Jones had failed to demonstrate that the district court’s application of § 922(g)(1) constituted clear or obvious error, and thus affirmed the decision of the lower court. View "USA v. Jones" on Justia Law

Sammy Tawakkol sued two Texas state officials, alleging that they violated his right to procedural due process when they notified him that he was required to register as a sex offender under Texas law. The district court ruled in Tawakkol's favor. However, the United States Court of Appeals for the Fifth Circuit found that Tawakkol's suit was barred by sovereign immunity and therefore the district court lacked jurisdiction to rule on the case.The case began when Tawakkol was required to register as a sex offender under the federal Sex Offender Registry and Notification Act (SORNA) because of a crime he committed while he was a cadet at the United States Air Force Academy. After he moved to Houston, Texas, state officials determined that he also needed to register as a sex offender under Texas's system. Tawakkol sued the state officials, alleging that their registration determination violated his procedural due process rights under the Fourteenth Amendment.The district court ruled in favor of Tawakkol, but the Court of Appeals vacated this decision and remanded the case back to the district court with instructions to dismiss for lack of jurisdiction. The Court of Appeals found that the suit was barred by sovereign immunity, a legal doctrine that prevents certain lawsuits against state officials. The court concluded that Tawakkol's case did not meet the criteria for an exception to sovereign immunity established in Ex parte Young, a Supreme Court case that allows lawsuits against state officials to prevent them from enforcing state laws that violate federal law.The court reasoned that unlike in Ex parte Young, the district court's order did not enjoin the state officials from enforcing a state law that violated federal law. Instead, the district court invalidated federal law and prohibited the state officials from enforcing a state law that was consistent with that federal law. The court determined that this type of relief fell outside the narrow parameters of the Ex parte Young exception and did not serve its purpose, which is to vindicate federal rights. View "Tawakkol v. Vasquez" on Justia Law

This case involves Rolando Villarreal who pleaded guilty to being a felon in possession of a firearm. His sentence was enhanced under the Armed Career Criminal Act (ACCA) due to a prior burglary and two prior aggravated assaults. Villarreal challenged the enhancement under 28 U.S.C. § 2255, arguing that his sentence was improperly enhanced under the ACCA's elements or force clause based on the predicate offense that allowed conviction for reckless conduct, a claim subsequently termed a "Borden claim."The United States Court of Appeals for the Fifth Circuit found that Villarreal did assert a Borden claim in his § 2255 motion and that his sentence was "in excess of the maximum authorized by law." This was due to the fact that, after the ruling in Borden v. United States, the convictions under the relevant aggravated assault statute could not constitute predicate offenses under the ACCA as they do not require the "physical use of force against the person of another."As a result, the Court of Appeals vacated Villarreal’s sentence and remanded the case back to the district court with instructions to resentence Villarreal without consideration of the ACCA. View "USA v. Villarreal" on Justia Law

In this case, the defendant, Sterling Robinson, was convicted by a jury on one count of possessing a firearm or ammunition as a convicted felon and one count of attempted obstruction of a federal proceeding. He appealed these convictions on the grounds of sufficiency challenges, errors relating to evidence admitted at trial, the trial court's jury instructions, and the prosecutor's remarks during opening and closing arguments. Robinson also appealed his sentence, arguing that the district court misunderstood its authority to order that his sentence run concurrently with another federal sentence.The case originated from an incident where Robinson's ex-girlfriend, Candace Anderson, accused him of shooting at her car while her nine-year-old son was inside. After the incident, Robinson repeatedly urged Anderson to change her story during phone calls from jail.The United States Court of Appeals for the Fifth Circuit affirmed Robinson's convictions, stating that there was sufficient evidence for a reasonable jury to conclude that Robinson was guilty beyond a reasonable doubt of the stated charges. The court held that the district court did not abuse its discretion in its admission of evidence, the failure to give an impeachment instruction, or any improper remarks by the prosecutor.However, the court agreed with Robinson's argument that the district court misunderstood its sentencing authority. The district court initially stated that Robinson’s sentence would run concurrently with a sentence imposed upon his revocation of supervised release, but later retracted this after the government pointed out that another judge had ordered the sentences to run consecutively. The appellate court clarified that one district court has no authority to instruct another district court on how to impose its sentence for a different offense in a different case. As a result, the court vacated Robinson’s term of imprisonment and remanded the case for a narrow resentencing limited to the sole issue of whether Robinson’s prison sentence in this case should run concurrently or consecutively with his other federal sentence. View "USA v. Robinson" on Justia Law

In a collision between two vessels on the Mississippi River, the United States Court of Appeals for the Fifth Circuit ruled that Louisiana law, not general maritime law, governs the burden of proof for the pilot's error.On January 3, 2019, the M/V STRANDJA, piloted by Captain Robert Johnson, drifted from its anchorage into the middle of the river, colliding with the M/V KIEFFER E. BAILEY, owned by Marquette Transportation Company Gulf-Inland LLC. The collision caused damage to both vessels. Marquette brought claims against STRANDJA's owner, Balkan Navigation Ltd, and manager, Navigation Maritime Bulgare JSC (collectively referred to as "Balkan"), alleging their negligence caused the collision.A jury found that Marquette was not negligent and that Balkan and Captain Johnson were each 50% at fault. The jury awarded Marquette $114,000 in damages and awarded Balkan $0 in damages. Both Balkan and Captain Johnson appealed the judgment.The Fifth Circuit affirmed the judgment that Marquette was not negligent, and therefore not liable for the accident. However, the court found that the district court erred in instructing the jury to apply general maritime law, which only requires a finding of ordinary negligence by a preponderance of the evidence, to the claim against Captain Johnson. Instead, the court held that Louisiana law, which requires clear and convincing evidence of gross negligence or willful misconduct, should have been applied.As a result, the court vacated the judgment against Balkan and Captain Johnson and remanded the case for a new trial, applying the correct standard of proof under Louisiana law. The court also ordered Marquette to amend its complaint within 14 days to allege admiralty jurisdiction as the jurisdictional basis for its claim against Balkan. View "Marquette Transportation Company Gulf-Inland, L.L.C. v. Navigation Maritime Bulgare" on Justia Law

In this case before the United States Court of Appeals for the Fifth Circuit, a state pretrial detainee, Rashaud L. Robinson, scheduled for a second trial, sought a writ of habeas corpus. Robinson claimed that when a poll of jurors at his 2021 trial showed ten of its members would acquit on four of five counts, retrial on those counts became barred under then-existing Louisiana law. The state trial court judge declared a mistrial instead, and the federal district court denied any relief.On appeal, the Court of Appeals held that that Robinson's claim was not about his release from or reduction in length or level of custody. Once it became clear that the arguments about acquittals did not apply to all counts, the suit was not about a release from or reduction in length or level of custody. The question was whether nonunanimous verdicts of acquittal prevented Robinson’s retrial on four counts. He was not requesting release from detention as he awaits trial on only one charge. Therefore, the court concluded that this Section 2241 habeas proceeding must be dismissed. The court did not evaluate the district court’s finding that when the state courts held Robinson had not been acquitted, those courts had relied at least in part on state law. The decision was based only on the unavailability of any relief appropriate in a habeas proceeding for Robinson’s claims. That was the only issue the court considered, and, solely for that reason, the court affirmed the district court’s denial of habeas relief. Though the court could not rule on the merits of Robinson’s arguments, nothing in this opinion should be interpreted as preventing Robinson from presenting similar arguments in the future as appropriate. View "Robinson v. Lopinto" on Justia Law