5th Circuit Case Commentaries

Fraudulent Inducement, Not Right-to-Control: Fifth Circuit Holds § 1348 Reaches Social‑Media Pump‑and‑Dump Schemes Without Proof of Victim Net Loss

Date: Oct 4, 2025

Fraudulent Inducement, Not Right-to-Control: Fifth Circuit Holds § 1348 Reaches Social‑Media Pump‑and‑Dump Schemes Without Proof of Victim Net Loss Introduction In United States v. Constantinescu,...

Emergency-Aid Entry and Marijuana-Odor Probable Cause Reaffirmed: United States v. Jackson (5th Cir. 2025)

Date: Oct 4, 2025

Emergency-Aid Entry and Marijuana-Odor Probable Cause Reaffirmed: United States v. Jackson (5th Cir. 2025) Court: United States Court of Appeals for the Fifth Circuit Date: October 2, 2025 Panel:...

Tacit Conspiracy with Dark Web Marketplace Operators: Fifth Circuit Affirms That Platform Facilitation Can Satisfy the Agreement Element in Narcotics Conspiracies

Date: Oct 4, 2025

Tacit Conspiracy with Dark Web Marketplace Operators: Fifth Circuit Affirms That Platform Facilitation Can Satisfy the Agreement Element in Narcotics Conspiracies Introduction In United States v....

No TWDA End-Run via Official-Capacity Pleading; Fifth Circuit Reaffirms Subjective Deliberate-Indifference Standard for Pretrial Detainee Medical Care

Date: Oct 3, 2025

No TWDA End-Run via Official-Capacity Pleading; Fifth Circuit Reaffirms Subjective Deliberate-Indifference Standard for Pretrial Detainee Medical Care Court: United States Court of Appeals for the...

FEGLIA “Receipt” Defined: Delivery to Employing-Office Personnel Suffices; No Indicia-of-Receipt or File-Presence Requirement (Metropolitan v. Vasquez, 5th Cir. 2025)

Date: Oct 3, 2025

FEGLIA “Receipt” Defined: Delivery to Employing-Office Personnel Suffices; No Indicia-of-Receipt or File-Presence Requirement Case: Metropolitan v. Vasquez, No. 24-11024 (5th Cir. Oct. 1, 2025) (per...

No Constructive Notice from Tracks Alone: Fifth Circuit Reaffirms Mississippi’s Temporal Proof Requirement in Slip‑and‑Fall Cases

Date: Oct 2, 2025

No Constructive Notice from Tracks Alone: Fifth Circuit Reaffirms Mississippi’s Temporal Proof Requirement in Slip‑and‑Fall Cases Introduction In Harrison v. Houchens Food Group, the United States...

“Actual Knowledge” Means an Actual Inference: Fifth Circuit Reaffirms Strict Pleading for K–12 Title IX Liability in Monroe v. Aldine ISD

Date: Oct 2, 2025

“Actual Knowledge” Means an Actual Inference: Fifth Circuit Reaffirms Strict Pleading for K–12 Title IX Liability in Monroe v. Aldine ISD Introduction In an unpublished per curiam decision, the...

No Heightened Review Without an Arguable Limitations Bar: Fifth Circuit Affirms Rule 41(b) Dismissal of a Post-Conviction Rule 41(g) Property-Return Action

Date: Oct 2, 2025

No Heightened Review Without an Arguable Limitations Bar: Fifth Circuit Affirms Rule 41(b) Dismissal of a Post-Conviction Rule 41(g) Property-Return Action Introduction In Sanusi v. United States,...

Explicit Warnings Suffice as “Lesser Sanctions”: Fifth Circuit Affirms Rule 41(b) Dismissal for Repeated Defiance of Deposition Orders in Lee v. Southwest Airlines

Date: Oct 1, 2025

Explicit Warnings Suffice as “Lesser Sanctions”: Fifth Circuit Affirms Rule 41(b) Dismissal for Repeated Defiance of Deposition Orders in Lee v. Southwest Airlines Introduction This commentary...

No Clearly Established Due Process Right in Inmate Craft‑Sale Proceeds: Fifth Circuit Grants Qualified Immunity in Savage v. Westcott

Date: Oct 1, 2025

No Clearly Established Due Process Right in Inmate Craft‑Sale Proceeds: Fifth Circuit Grants Qualified Immunity in Savage v. Westcott Introduction In Savage v. Westcott, the United States Court of...

Contract, Not Takings: Fifth Circuit Holds Municipal Refusal to Extend a Development Agreement Is Commercial (Non‑Sovereign) Conduct

Date: Sep 25, 2025

Contract, Not Takings: Fifth Circuit Holds Municipal Refusal to Extend a Development Agreement Is Commercial (Non‑Sovereign) Conduct Introduction In Mesquite Asset Recovery Group, L.L.C. v. City of...

No Safe Harbor in Delay: Fifth Circuit Confirms EPA May Disapprove Overdue Good Neighbor SIPs Using Updated Modeling and Requires Independent “Maintenance” Analysis Beyond Formal Nonattainment Designations

Date: Sep 25, 2025

No Safe Harbor in Delay: Fifth Circuit Confirms EPA May Disapprove Overdue Good Neighbor SIPs Using Updated Modeling and Requires Independent “Maintenance” Analysis Beyond Formal Nonattainment...

No Standalone Due‑Process Right to Obtain DNA Electronic Files Outside Court‑Supervised Habeas Discovery: The Fifth Circuit’s Decision in In re Blaine Milam

Date: Sep 24, 2025

No Standalone Due‑Process Right to Obtain DNA Electronic Files Outside Court‑Supervised Habeas Discovery: The Fifth Circuit’s Decision in In re Blaine Milam Introduction In a consolidated capital...

No Due Process Right to Pre‑Habeas Access to Raw DNA Data: Fifth Circuit Upholds Texas’s Court‑Controlled Postconviction Discovery Regime and Rejects § 1983 Mandamus

Date: Sep 24, 2025

No Due Process Right to Pre‑Habeas Access to Raw DNA Data: Fifth Circuit Upholds Texas’s Court‑Controlled Postconviction Discovery Regime and Rejects § 1983 Mandamus Introduction In Milam v....

No Equitable Tolling for INA’s One-Motion Rule: The Fifth Circuit’s Categorical Bar on Tolling the Numerical Limit in Motions to Reopen

Date: Sep 13, 2025

No Equitable Tolling for INA’s One-Motion Rule: The Fifth Circuit’s Categorical Bar on Tolling the Numerical Limit in Motions to Reopen Introduction In Garcia Morin v. Bondi, No. 24-60590 (5th Cir....

States May Regulate 340B Patient-Level Distribution: Fifth Circuit Declines to Enjoin Mississippi’s Contract-Pharmacy “Non‑Interference” Law

Date: Sep 13, 2025

States May Regulate 340B Patient-Level Distribution: Fifth Circuit Declines to Enjoin Mississippi’s Contract-Pharmacy “Non‑Interference” Law Introduction In AbbVie v. Fitch, the U.S. Court of Appeals...

Fifth Circuit Clarifies That Prior Probation Does Not Offset the Statutory Maximum for Supervised Release and That Cumulative Brady Material Cannot Support § 2255 Relief

Date: Sep 12, 2025

Fifth Circuit Clarifies That Prior Probation Does Not Offset the Statutory Maximum for Supervised Release and That Cumulative Brady Material Cannot Support § 2255 Relief Introduction In United States...

Probation Is Not Supervised Release: Fifth Circuit Rejects Offset Theory and Reaffirms Cumulative Brady Evidence Is Immaterial — United States v. Hoffman (5th Cir. 2025)

Date: Sep 12, 2025

Probation Is Not Supervised Release: Fifth Circuit Rejects Offset Theory and Reaffirms Cumulative Brady Evidence Is Immaterial — United States v. Hoffman (5th Cir. 2025) Introduction In United States...

Temporal Proximity and Similarity, Without Regularity, Can Establish Relevant Conduct for Drug Trafficking (5th Cir. Unpublished)

Date: Sep 12, 2025

Temporal Proximity and Similarity, Without Regularity, Can Establish Relevant Conduct for Drug Trafficking (5th Cir. Unpublished) Case: United States v. Griffin, No. 24-50247 (5th Cir. Sept. 11,...

Double Deference Reaffirmed: Showing Strickland Prejudice on Competency Claims Requires Proof of Likely Incompetence, Not Just Eligibility for a Competency Trial

Date: Sep 12, 2025

Double Deference Reaffirmed: Showing Strickland Prejudice on Competency Claims Requires Proof of Likely Incompetence, Not Just Eligibility for a Competency Trial Case: Lizcano v. Guerrero Court:...