Introduction

In First Baptist Church of Iowa, Louisiana v. Church Mutual Insurance Co., S.I. (“First Baptist Church II”), the United States Court of Appeals for the Fifth Circuit revisited a protracted insurance-coverage dispute arising out of Hurricane Laura. The litigation’s second appearance before the court provided an opportunity to delineate the contours of the mandate rule, the law-of-the-case doctrine, and the discretion district courts retain when recalculating damages on remand.

The plaintiff–appellee, First Baptist Church of Iowa, Louisiana (the “Church”), sought additional insurance proceeds for hurricane damage to its multi-structure property. The defendant–appellant, Church Mutual Insurance Company, S.I. (“CM Insurance”), challenged only one aspect of the district court’s amended judgment: the award of electrical-repair damages exceeding the $4,500 figure the appellate court referenced in the first appeal (“First Baptist Church I”).

Because the panel affirmed the district court’s revised award, its decision cements three principles that will guide future remand practice in the Fifth Circuit:

1. Appellate mandates restrict district courts only to the extent expressly or necessarily implied;
2. On remand, a district court may rely on recalculations rooted in record evidence without formally re-admitting documents; and
3. Refusal to reopen the evidentiary record will be overturned only upon a showing of injustice or abuse of discretion.

Summary of the Judgment

The Fifth Circuit affirmed the district court’s post-remand damages award for electrical repairs in the Church’s main building. It held that:

• The prior mandate barred awards exceeding $4,500 only for the sanctuary; it did not limit damages for the rest of the church building.
• The district court did not err by using the Church’s revised estimate, because the estimate merely adjusted pricing dates with data already admitted at trial.
• The district court acted within its discretion in denying CM Insurance’s request to introduce a new expert estimate and in refusing to reopen the evidentiary record.

Accordingly, CM Insurance’s appeal was rejected, and the district court’s amended judgment was affirmed in full.

Analysis

Precedents Cited and Their Influence

• First Baptist Church I, 105 F.4th 775 (5th Cir. 2024) – The panel’s earlier decision supplied the operative mandate: damages must be calculated using prices “as of the time of loss,” slab repair was disallowed, and electrical-repair damages for the sanctuary could not exceed $4,500. First Baptist Church II interprets the scope of that mandate.
• Franklin v. Regions Bank, 125 F.4th 613 (5th Cir. 2025) – Quoted for standards governing interpretation of remand orders and interplay between mandate rule and district-court discretion.
• White v. Murtha, 377 F.2d 428 (5th Cir. 1967) – Foundational articulation of the law-of-the-case doctrine.
• Perez v. Stephens, 784 F.3d 276 (5th Cir. 2015)
• Crowe v. Smith, 261 F.3d 558 (5th Cir. 2001) – Both cited for the principle that issues decided “explicitly or by necessary implication” become binding on remand.
• Bell Petroleum Services, Inc., 64 F.3d 202 (5th Cir. 1995); Jones & Laughlin Steel Corp. v. Pfeifer, 462 U.S. 523 (1983) – Confirm district courts may permit new evidence on remand unless expressly forbidden.
• Garcia v. Woman’s Hospital of Texas, 97 F.3d 810 (5th Cir. 1996) – Provides abuse-of-discretion standard for refusal to reopen the record.

Legal Reasoning of the Court

1. Mandate Interpretation. The panel conducted a de novo review of its prior remand instructions. By closely parsing language from First Baptist Church I—especially the phrase “in the sanctuary”—the court concluded that its earlier reversal concerned only sanctuary wiring. Because the first opinion repeatedly acknowledged that other portions of the building remained unrepaired, it would be illogical to assume damages there were capped.
2. Application of Law-of-the-Case. Under established doctrine, a district court cannot revisit matters “decided explicitly or by necessary implication.” The panel reasoned that capping sanctuary damages at $4,500 was explicit, but limiting damages elsewhere was neither explicit nor implied. Therefore, the district court properly awarded additional sums for other rooms.
3. Reliance on a “Revised” Estimate. Because Harper Chambers’ updated estimate merely substituted a September 2020 price list—the same list already introduced by CM Insurance’s expert—no new substantive evidence was offered. Thus, the calculation was grounded in the existing record, satisfying both evidentiary and due-process concerns.
4. Refusal to Reopen the Record. CM Insurance’s proffered post-trial affidavit and estimate required reopening the evidentiary record. The appellate court applied an abuse-of-discretion standard and highlighted two factors:
   • Probative Value: The new materials added little, as CM Insurance had already argued that non-sanctuary repairs should be $0.
   • Potential Prejudice/Injustice: The district court’s refusal did not “work an injustice,” particularly because CM Insurance cross-examined Chambers at trial and failed to request additional discovery earlier.

Potential Impact of the Decision

First Baptist Church II is poised to influence remand practice in three significant ways:

• Precision in Drafting Mandates. Appellate panels within the Fifth Circuit may now draft more explicit remand instructions to avoid unintended elasticity.
• Strategic Litigation on Remand. Litigants must recognize that unless the mandate expressly reopens discovery, attempts to introduce new evidence face a steep hurdle.
• Insurance-coverage Valuations. By upholding the use of price lists contemporaneous with the loss date—but permitting recalculations based on existing record data—the ruling offers a pragmatic template for disputed property-damage claims, particularly in catastrophic-loss contexts where repair work spans years.

Complex Concepts Simplified

• Law-of-the-Case Doctrine: Once an appellate court decides a legal question, that decision governs later stages of the same matter. Think of it as a “no-redo” rule for issues already settled between the same parties.
• Mandate Rule: The district court must follow both the literal words and the underlying spirit of the appellate court’s instructions—and do nothing beyond them.
• Reopening the Record: After a trial ends, the “record” is closed. A party who wants to add new evidence later must convince the judge to reopen it, which happens rarely and only for compelling reasons.
• Abuse-of-Discretion Standard: An appellate court will reverse a district court’s decision only if it was plainly unreasonable, arbitrary, or resulted in injustice—not merely because the appellate judges would have ruled differently.
• Contemporaneous Valuation: Insurance policies typically require property values to be calculated “as of the time of loss.” Using price lists from months or years later inflates damages and violates this clause.

Conclusion

First Baptist Church II refines Fifth Circuit jurisprudence on the interaction between appellate mandates and trial-court discretion. By affirming the district court’s broader damages award—despite an earlier directive capping sanctuary repairs—the decision underscores that mandates should be read exactly as drafted, no more and no less. It also blesses pragmatic recalculations derived from existing record data and sets a high bar for parties seeking to reopen the record post-trial.

Practitioners litigating remanded cases must, therefore, (1) parse mandate language meticulously, (2) anchor recalculations to evidence already in the record, and (3) be prepared to justify any request for additional evidence as truly necessary to prevent injustice. The opinion’s clear, structured guidance will likely streamline post-remand proceedings across the Fifth Circuit and beyond.