The 5th U.S. Circuit Court of Appeals has reversed a sanctions order issued by U.S. District Judge Lynn Hughes of Houston. The 5th Circuit ruled that a lawyer’s filing of a "sexually-explicit Internet chat" in an employment case was not sanctionable conduct; rather it was "zealous representation of his client."

The background to the 5th Circuit’s May 14 decision in Kenyon International Emergency Services Inc. v. Mark Malcolm, et al. is as follows, according to the decision.