Justia Civil Procedure Opinion Summaries

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

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

The plaintiff, who is civilly committed as a sexually violent predator at the Texas Civil Commitment Center, brought a pro se lawsuit under 42 U.S.C. § 1983 against the Commissioner of the Texas Department of Family Protective Services and the Executive Commissioner of the Texas Health and Human Services Commission. He alleged that these agencies failed to investigate his reports of misconduct and abuse at the facility, claiming violations of his Fourteenth Amendment rights to equal protection and due process, as well as rights under the Bill of Rights for Mental Health Patients. The plaintiff asserted that he should be able to file complaints with these agencies rather than being required to use the internal grievance procedure of the Texas Civil Commitment Office.The United States District Court for the Western District of Texas screened the complaint under 28 U.S.C. § 1915(e)(2)(B) because the plaintiff was proceeding in forma pauperis. The district court found that the plaintiff failed to state a claim for relief and that amendment would be futile, so it dismissed the complaint without prejudice. The plaintiff appealed, arguing that he had adequately stated equal protection and due process claims, that he should have been allowed to amend his complaint, and that the district court was biased.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to state an equal protection claim because he was not similarly situated to other Texas citizens and the different grievance procedures had a rational basis. The court also found no protected liberty or property interest to support a due process claim and concluded that the alleged conduct did not rise to the level of a substantive due process violation. The court further held that amendment would have been futile and found no evidence of judicial bias. The plaintiff’s motion for appointment of counsel was denied. View "Dunsmore v. Muth" on Justia Law

A group of former employees, most of whom are Black, brought claims against their former employer, an IT company, and its parent corporation. They alleged race discrimination, a hostile work environment, and retaliation for opposing discrimination, citing actions such as terminations, denials of promotions, and workplace policies they believed targeted Black employees. The plaintiffs described being subjected to stricter rules, surveillance, and less favorable treatment compared to non-Black employees. One plaintiff, who is white, also alleged retaliation for supporting his Black colleagues.The United States District Court for the Eastern District of Texas granted summary judgment to the employer on all hostile work environment claims and on certain discrimination and retaliation claims, finding insufficient evidence of an “ultimate employment decision” as required by then-controlling precedent. The court also excluded some witness testimony. At trial, a jury found for nine plaintiffs on discrimination and retaliation claims, awarding substantial damages. However, the district court granted judgment as a matter of law (JMOL) to the employer on most claims, finding insufficient evidence to support the jury’s verdicts, and to the parent company, concluding it was not an “integrated enterprise” with the employer. The court also granted a new trial on two retaliation claims, finding the verdicts contrary to the weight of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case. It vacated the summary judgment on certain discrimination and retaliation claims, remanding those for further proceedings in light of new precedent that broadened the definition of adverse employment actions. The Fifth Circuit affirmed the district court’s rulings in all other respects, including the grants of JMOL, the new trial orders, the exclusion of witness testimony, and the finding that the parent company was not liable as an integrated enterprise. View "Yarbrough v. SlashSupport" on Justia Law

A citizen of Mexico, who had been a lawful permanent resident in the United States since 1982, was convicted twice for aggravated assault with a deadly weapon—first in 2011 for shooting his ex-wife and again in 2018 for assaulting a roommate with a knife. These felony convictions led the Department of Homeland Security to initiate removal proceedings against him under Section 237(a)(2)(C) of the Immigration and Nationality Act, which concerns firearm offenses. An immigration judge ordered his removal after he completed his sentences, finding him ineligible for relief due to his convictions.The Board of Immigration Appeals (BIA) affirmed the removal order in 2020. The individual’s first petition for review to the United States Court of Appeals for the Fifth Circuit was dismissed as untimely. In 2022, he filed his first motion to reopen or reconsider with the BIA, arguing that a Supreme Court decision, Borden v. United States, changed the legal landscape regarding his removability. The BIA denied this motion, finding Borden inapplicable because his removal was based on a firearm offense, not an aggravated felony, and that the motion was untimely. In 2024, he filed a second motion to reopen, again citing Borden and seeking equitable tolling of both the time and numerical limits on motions to reopen. The BIA denied this second motion, holding that the statutory limit of one motion to reopen applied and that equitable tolling did not extend to the numerical bar.The United States Court of Appeals for the Fifth Circuit reviewed the BIA’s denial. The court held that the statutory “number bar” in the INA, which generally allows only one motion to reopen, is not subject to equitable tolling. The court dismissed the petition in part and denied it in part, concluding that the BIA did not err in refusing to reopen the removal proceedings. View "Garcia Morin v. Bondi" on Justia Law

A 78-year-old inmate in a Texas men’s prison, who identifies as a transgender woman, sought sex-reassignment surgery after being diagnosed with gender dysphoria in 2013. The inmate received hormone therapy and was chemically castrated, but was ultimately denied surgery by prison medical staff. The inmate alleged that state officials discriminated by providing reconstructive vaginoplasty to female inmates while denying similar surgery to transgender inmates, claiming a violation of the Equal Protection Clause.The United States District Court for the Southern District of Texas initially denied motions to dismiss based on sovereign immunity, finding that the inmate was similarly situated to cisgender female inmates and that the claims met the requirements of the Ex parte Young exception to sovereign immunity. On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit vacated the district court’s orders, holding that the inmate had not adequately pled that any defendant was sufficiently connected to enforcement of the challenged policy. On remand, after further proceedings and discovery, the district court granted judgment on the pleadings, concluding that the defendants were either improper under Ex parte Young or that the requested relief was not permitted, and dismissed the lawsuit for lack of jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal, holding that the inmate lacked standing. The court found that the alleged injury was not fairly traceable to the defendants, as there was no evidence that any treating physician had determined the inmate was a suitable candidate for surgery or would refer the inmate for the procedure. Without such evidence, the injury could not be redressed by a favorable judicial decision against the defendants. View "Haverkamp v. Linthicum" on Justia Law

Plaintiffs initiated a lawsuit against eleven defendants, alleging a scheme involving breach of employment agreements, misappropriation of funds, embezzlement, and fraud. The suit was originally filed in the Circuit Court of Harrison County, Mississippi. Defendants removed the case to the United States District Court for the Southern District of Mississippi, citing diversity jurisdiction. Plaintiffs sought to remand the case to state court, relying on a provision in three defendants’ contracts that specified venue in Harrison County, Mississippi, and included language about consent to personal jurisdiction and venue solely within those forums, along with a waiver of objections to those forums.The United States District Court for the Southern District of Mississippi interpreted the contractual provision as a waiver of the defendants’ right to remove the case to federal court. The district court reasoned that the provision gave the first-filing party the sole right to choose the court, and that by waiving objections to venue and personal jurisdiction, the defendants had also waived their removal rights. Consequently, the district court remanded the case to state court.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s interpretation of the contractual waiver de novo, applying Mississippi law. The Fifth Circuit held that the contract provision did not constitute a clear and unequivocal waiver of the defendants’ right to remove the case to federal court. The court found that the language regarding venue and jurisdiction could reasonably refer to geographic location and did not explicitly or implicitly waive removal rights, especially since the contract contemplated litigation in both state and federal courts in Harrison County. The Fifth Circuit reversed the district court’s remand order. View "Gulf Coast Pharmaceuticals Plus, L.L.C. v. RFT Consulting" on Justia Law

A dispute arose over the ownership of real property located at 829 Yale Street in Houston, Texas. In 2019, Nicholas Fugedi, acting as trustee for the Carb Pura Vida Trust, initiated a quiet title action against several defendants. The central issue became whether the trust, and specifically Fugedi’s appointment as trustee, was used as a device to create diversity jurisdiction in federal court, given that Fugedi was a citizen of Michigan while the underlying parties were Texas residents.Initially, the United States District Court for the Southern District of Texas ruled against Fugedi, finding the deed void under Texas law. On appeal, the United States Court of Appeals for the Fifth Circuit reversed that decision but noted that the district court could consider new evidence on remand regarding whether the trust was a sham created to manufacture diversity jurisdiction. On remand, the district court found that Fugedi had been appointed as a sham trustee solely to create diversity jurisdiction, and dismissed the case for lack of subject matter jurisdiction under 28 U.S.C. § 1359.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo, and its factual findings for clear error. The Fifth Circuit held that 28 U.S.C. § 1359 applies to trusts and that a trust can be used as a device to improperly manufacture diversity jurisdiction. The court found no clear error in the district court’s factual findings that Fugedi was appointed as a sham trustee for the purpose of creating federal jurisdiction. Accordingly, the Fifth Circuit affirmed the district court’s dismissal for lack of subject matter jurisdiction. View "Fugedi v. Initram" 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

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