Case Explained: Summary Calendar Jane Doe Plaintiff— v. Mark A. Gipson Defendant—

Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-15

The Fifth Circuit affirmed the district court’s denial of a motion for mistrial in a civil case involving the unlawful disclosure of intimate images under 15 U.S.C. § 6851 and Texas Civil Practices and Remedies Code § 98B. The court held that the district judge did not abuse his discretion in rejecting the defendant’s claim that a venireperson’s statement about reading a newspaper article from 2012 tainted the jury. Applying an abuse of discretion standard, the Fifth Circuit accorded great weight to the trial court’s finding that the extrinsic information was non-specific, unrelated to the present case, and so remote in time that it did not likely cause prejudice. Because the defendant failed to demonstrate that the extrinsic influence likely caused bias, the judgment stands as affirmed.

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