50 Fair empl.prac.cas. 681, 50 Empl. Prac. Dec. P 39,203 Page Ann McIncrow v. Harris Cnty., Metro. Transit Auth., 878 F.2d 835 (5th Cir. 1989). · Go Syfert
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50 Fair empl.prac.cas. 681, 50 Empl. Prac. Dec. P 39,203 Page Ann McIncrow v. Harris Cnty., Metro. Transit Auth., 878 F.2d 835 (5th Cir. 1989). Cases Citing This Book View Copy Cite
G Cite
cited 2× by 2 distinct cases, 1995–2024 · …reasoning is vague or simply left unsaid, there is little opportunity for effective review. at p. 836 ✓
22 citation events (17 in the last 25 years) across 2 distinct courts.
Strongest positive: Ramey v. Bessent (ca5, 2025-10-22)
Treatment trajectory · 1989 → 2026 · click a year to view as-of
1989 2007 2026
Top citers, strongest first. 12 distinct citers. How cited ↗
cited Cited as authority (rule) Ramey v. Bessent
5th Cir. · 2025 · confidence medium
McIncrow v. Harris Cnty., 878 F.2d 835, 836 (5th Cir. 1989).
discussed Cited as authority (rule) Lopez v. Ramirez
5th Cir. · 2024 · confidence medium
The district court’s lack of any explanation about the basis for its denial of Defendants’ motion to dismiss precludes effective appellate review in this case. 7 This is particularly _____________________ 3 Carswell v. Camp, 54 F.4th 307, 310 (5th Cir. 2022) (citations omitted), cert. denied, 144 S. Ct. 73 (2023) (mem). 4 Lopez, 2022 WL 3230442 , at *1 (quoting Backe v. LeBlanc, 691 F.3d 645, 648 (5th Cir. 2012)). 5 Solis v. Serrett, 31 F.4th 975, 981 (5th Cir. 2022) (citing Meadours v. Ermel, 483 F.3d 417 , 421–22 (5th Cir. 2007)). 6 See Meadours, 483 F.3d at 421–22 (“The district c…
discussed Cited as authority (rule) Steve Lacroix v. Marshall County, Mississip
5th Cir. · 2011 · confidence medium
This is because we have "little opportunity for effective review” when a district court’s "reasoning is vague or simply left unsaid.” Id. (citing McIncrow v. Harris Cnty., 878 F.2d 835, 836 (5th Cir.1989)).
cited Cited as authority (rule) Gutierrez v. Hiatt
5th Cir. · 2009 · signal: cf. · confidence medium
Cf. McIncrow v. Harris County, 878 F.2d 835, 836 (5th Cir.1989).
cited Cited as authority (rule) Liberty Mutual Insurance v. Brown
5th Cir. · 2004 · confidence medium
McInrow v. Harris County, 878 F.2d 835, 836 (5th Cir.1989).
discussed Cited as authority (rule) United States v. Contreras
S.D. Tex. · 2000 · confidence medium
This is the theme: “Although nothing [in the rules] technically requires a statement of reasons by a trial judge ... we have many times emphasized the importance of a detailed discussion by the trial judge.” McIncrow v. Harris County, 878 F.2d 835, 835 (5th Cir.l989)(quoting Heller v. Namer, 666 F.2d 905, 911 (5th Cir.1982))(emphasis added), as quoted in O’Neill v. Air Line Pilots Ass’n Intern., 886 F.2d 1438, 1443 (5th Cir.1989), rev’d, 499 U.S. 65 , 111 S.Ct. 1127 , 113 L.Ed.2d 51 (1991)(affirming trial court still without a trial-court opinion).
cited Cited as authority (rule) Davis v. Bayless
5th Cir. · 1995 · confidence medium
When the district court’s “reasoning is vague or simply left unsaid, there is little opportunity for effective review.” McIncrow v. Harris County, 878 F.2d 835, 836 (5th Cir.1989).
discussed Cited as authority (rule) Joseph E. O'Neill v. Air Line Pilots Association, International
5th Cir. · 1989 · confidence medium
R.Civ.P. 56, governing summary judgment, technically requires a statement of reasons by a trial judge for granting a motion for summary judgment, we have many times emphasized the importance of a detailed discussion by the trial judge.” McIncrow v. Harris County, 878 F.2d 835, 835 (5th Cir.1989), quoting, Heller v. Namer, 666 F.2d 905, 911 (5th Cir.1982) (footnote omitted).
discussed Cited as authority (rule) JESUS G. MUNOZ; MANUAL MUNOZ, JR v. VERNE ORR; ET AL
unknown court · confidence medium
In such cases, we have not hesitated to remand the case for an illumination of the court’s analysis through some formal or informal statement of reasons.’” McInrow v. Harris County, 878 F.2d 835, 836 (5th Cir. 1989) (quoting Myers v. Gulf Oil Corp., 731 F.2d 281, 284 (5th Cir. 1984)); see also Davis v. Bayless, 70 F.3d 367, 376 (5th Cir. 1995) (“[W]e have required that the district court explain its reasons in sufficient detail to allow this Court to determine whether the district court applied the proper legal rule.”).
discussed Cited "see" United States v. Flemons
5th Cir. · 2008 · signal: see · confidence high
See McIncrow v. Harris County, 878 F.2d 835 (5th Cir. 1989) (" ‘When we have no notion of the basis for a district court's decision, because its reasoning is vague or simply left unsaid, there is little opportunity for effective review.
cited Cited "see, e.g." Alexander v. Taft
5th Cir. · 2025 · signal: see, e.g. · confidence medium
See, e.g., McInrow v. Harris County, 878 F.2d 835, 836 (5th Cir. 1989).
cited Cited "see, e.g." Alexander v. Taft
5th Cir. · 2025 · signal: see, e.g. · confidence medium
See, e.g., McInrow v. Harris Cnty., 878 F.2d 835, 836 (5th Cir. 1989).
Retrieving the full opinion text from the archive…
Page Ann McINCROW, Plaintiff-Appellant,
v.
HARRIS COUNTY, Et Al., Defendants, Metropolitan Transit Authority, Defendant-Appellee
88-6056.
Court of Appeals for the Fifth Circuit.
Jul 28, 1989.
878 F.2d 835
1989 U.S. App. LEXIS 10961
1989 WL 75719
Page Ann Mclncrow, Houston, Tex., pro se., Paula J. Alexander, Houston, Tex., for defendant-appellee.
Gee, Williams, Higginbotham.
Cited by 16 opinions  |  Published
GEE, Circuit Judge:

Appellant Page Ann Mclncrow (Mcln-crow) sued Harris County, Texas, the City of Houston, and Houston’s Metropolitan Transit Authority (Metro) for discrimination based on age, race, and sex. Mcln-crow alleged that because of her characteristics, Metro refused to hire her in 1981, 1982, and 1985. Metro filed a motion for summary judgment and Mclncrow responded. After hearing argument on the motion, the district court granted Metro summary judgment. Mclncrow timely appealed.

In its summary judgment motion, Metro noted that Mclncrow failed to state under which legal theory she was proceeding. Assuming Mclncrow was suing under Title VII, Metro contended that 1) Mclncrow’s failure to obtain a right-to-sue letter precluded the district court from addressing all of her claims, See 42 U.S.C. § 2000e-5(b), (f)(1); 2) her claims of discrimination in 1981 and 1982 were time-barred by Title VII; and 3) laches precluded her claims of discrimination in 1981 and 1982. Assuming Mclncrow was suing under the Age Discrimination Act, 29 U.S.C. § 621 et seq., Metro argued 1) that Mcln-crow’s failure to obtain a right-to-sue letter precluded the district court from addressing all of her claims, see 29 U.S.C. § 626(d); and 2) laches precluded her claims of discrimination occurring in 1981 and 1982. Assuming that Mclncrow was suing under 42 U.S.C. § 1981, Metro argued that 1) her claims of discrimination occurring in 1981 and 1982 were barred by a) the applicable statute of limitations, and b) laches; 2) section 1981 provided no remedy for alleged age and sex discrimination; and 3) Mclncrow could not show adequately the requisite discrimination. The district court granted summary judgment for Metro without stating its reasons for doing so.

“Although nothing in Fed.R.Civ.P. 56, governing summary judgment, technically requires a statement of reasons by a trial judge for granting a motion for summary judgment, we have many times emphasized[*836] the importance of a detailed discussion by the trial judge.” Heller v. Namer, 666 F.2d 905, 911 (5th Cir.1982) (footnote omitted.) “When, [however], we have no notion of the basis for a district court’s decision, because its reasoning is vague or simply left unsaid, there is little opportunity for effective review. In such cases, we have not hesitated to remand the case for an illumination of the court’s analysis through some formal or informal statement of reasons.” Myers v. Gulf Oil Corp., 731 F.2d 281, 284 (5th Cir.1984) (footnotes omitted).

In this case Mclncrow asserted three instances of discrimination, possibly under three different statutory schemes. Metro offered nine arguments in support of its motion for summary judgment. The district court granted Metro’s motion for summary judgment without stating its reasons for doing so. Under these circumstances we are unable to review the district court’s decision in an effective manner. Therefore, the order of the district court is VACATED and the case is REMANDED to permit the district court to state the reasons for its decision.