Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

Three individuals were convicted under a federal law that prohibits those with prior misdemeanor convictions for domestic violence from possessing firearms or ammunition. Each had a history of violent conduct against intimate partners, and after their misdemeanor convictions under state law, they were later found in possession of firearms, leading to federal charges under 18 U.S.C. § 922(g)(9).Prior to this appeal, each defendant was convicted in a United States District Court—one in the Northern District of California and two in the District of Alaska—of violating § 922(g)(9). The convictions were based on evidence that after their state-level domestic violence misdemeanor convictions, they knowingly possessed firearms. Following their convictions, the defendants appealed, arguing that § 922(g)(9) is unconstitutional under the Second Amendment, both on its face and as applied to them.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court applied the framework established by New York State Rifle & Pistol Association, Inc. v. Bruen and United States v. Rahimi, and concluded that the plain text of the Second Amendment covers the appellants’ conduct but that the government demonstrated § 922(g)(9) is consistent with the nation’s historical tradition of firearm regulation. The court rejected both the facial and as-applied constitutional challenges, holding that Congress may categorically disarm those convicted of misdemeanor domestic violence without individualized findings of future dangerousness. The court further held that § 922(g)(9) is constitutional as applied to these appellants and affirmed the judgments of conviction. View "USA V. MARTINEZ" on Justia Law

A claimant applied for disability insurance benefits and supplemental security income, alleging a range of physical and mental health impairments. After an initial denial and an earlier remand from the district court, the claimant appeared before a new administrative law judge (ALJ). At the hearing, a vocational expert (VE) testified about the number of jobs in the national economy that someone with the claimant’s limitations could perform. The VE identified three specific jobs and provided job-number estimates, relying on sources such as SkillTRAN and manufacturer databases. The claimant then submitted post-hearing objections and contrary job-number evidence, using similar data sources, including SkillTRAN and the U.S. Census Bureau, to show far fewer available jobs or, in some cases, none at all.The ALJ briefly acknowledged the claimant’s contrary evidence but found it unpersuasive, stating that the VE’s testimony was more reliable due to his professional experience. The Appeals Council denied review, and the claimant then challenged the decision in the United States District Court for the District of Oregon. The district court affirmed, reasoning that the claimant’s alternative job numbers lacked probative value because the evidence did not sufficiently explain the methodology or expertise involved in generating those numbers.On appeal, the United States Court of Appeals for the Ninth Circuit found that the claimant’s counter evidence was both significant and probative, as it was generated using data sources and methods frequently relied upon by the Social Security Administration and showed large discrepancies with the VE’s estimates. The Ninth Circuit held that the ALJ erred by failing to adequately address and resolve the inconsistencies between the competing job-number evidence. The court reversed the district court’s decision and remanded the matter to the agency for further proceedings to resolve these discrepancies. View "POWLEY V. BISIGNANO" on Justia Law

A healthcare provider operating as a covered entity under the federal Section 340B Drug Pricing Program purchased pharmaceuticals from several drug manufacturers. The provider alleged that these manufacturers engaged in a fraudulent scheme by knowingly charging prices for drugs that exceeded the statutory ceiling, resulting in inflated reimbursement claims submitted to Medicaid, Medicare, and other government-funded programs. The provider did not seek compensation for its own overcharges, but instead brought a qui tam action under the False Claims Act (FCA), seeking to recover losses on behalf of the federal and state governments.The United States District Court for the Central District of California dismissed the complaint with prejudice. It reasoned that, under the Supreme Court’s holding in Astra USA, Inc. v. Santa Clara County, Section 340B does not confer a private right of action for covered entities to sue drug manufacturers over pricing disputes; such claims must instead be pursued through the Section 340B Administrative Dispute Resolution process. The district court concluded that the provider’s FCA claims were essentially attempts to enforce Section 340B and should therefore be barred.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The appellate court held that the provider’s FCA claims were not barred by the absence of a private right of action under Section 340B or by the Astra decision, because the action was brought to remediate fraud against the government and not to recover personal losses or enforce Section 340B directly. The court further found that the provider had plausibly pleaded falsity under the FCA. The Ninth Circuit remanded the case for further proceedings. View "ADVENTIST HEALTH SYSTEM OF WEST V. ABBVIE INC." on Justia Law

Cruz Torres-Gonzalez was convicted in 2014 for illegal reentry into the United States and for making false statements to federal officers. He received concurrent 35-month sentences for these offenses. In 2024, he was again convicted of illegal reentry. During sentencing for the 2024 conviction, the district court considered his prior convictions and applied sentencing enhancements under the United States Sentencing Guidelines, including an eight-level enhancement based on the 35-month sentence for his prior false-statement conviction.After his 2024 conviction in the United States District Court for the Southern District of California, Torres-Gonzalez objected to the eight-level enhancement. He argued that the sentence for his false-statement offense was not truly independent, as it had been grouped with his illegal reentry conviction in 2014, which carried the highest offense level. He asserted that this grouping made it impossible to determine the appropriate enhancement, and asked the court to apply a lesser, four-level enhancement instead. The district court acknowledged that the grouped sentence likely affected the length of the false-statement sentence but concluded that the guidelines, as written, required the eight-level enhancement. The court imposed a sentence of 51 months.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo. The appellate court held that the district court correctly applied the guidelines. It found no ambiguity in the relevant guideline provisions and determined that the length of the prior sentence, even if grouped, was the proper basis for the enhancement. The Ninth Circuit affirmed the sentence imposed by the district court. View "USA V. TORRES-GONZALEZ" on Justia Law

Susan Cox, a resident of Albion, Washington, died from an alleged overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Susan’s husband, Mark Cox, and her estate initiated a wrongful-death and survivor action against Dr. Marciano and Gritman Medical Center after Susan’s death. The Coxes had lived in Washington, while Dr. Marciano and Gritman are based in Idaho, with all medical treatment having taken place in Idaho. However, at Susan’s request, her prescriptions were regularly transmitted by Dr. Marciano and Gritman to pharmacies in Washington, and Gritman engaged in marketing and accepted patients from the Washington area.The United States District Court for the Eastern District of Washington dismissed the action for lack of personal jurisdiction over the Idaho-based defendants, holding that Washington’s long-arm statute did not reach them and the exercise of jurisdiction would violate due process. The district court also denied the plaintiffs’ request for jurisdictional discovery relating to general personal jurisdiction over Gritman, and did not address the issue of venue.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The Ninth Circuit held that the district court’s exercise of personal jurisdiction over Dr. Marciano and Gritman Medical Center was proper under both Washington’s long-arm statute and the Due Process Clause. The court found that the defendants had sufficient minimum contacts with Washington, as they cultivated relationships with Washington residents and regularly transmitted prescriptions to Washington pharmacies in compliance with Washington law. The court also held that venue was proper in the Eastern District of Washington because a substantial part of the events underlying the claims occurred there. The Ninth Circuit remanded the case for further proceedings and affirmed the dismissal only as to one defendant who was conceded to be properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

A federal land exchange was mandated by the Southeast Arizona Land Exchange and Conservation Act, requiring the United States Forest Service to transfer approximately 2,500 acres of National Forest land, including Oak Flat—a site of religious significance to the Apache—to Resolution Copper Mining, LLC, in exchange for over 5,000 acres of private land. The legislation included requirements for tribal consultation, land appraisal, and the preparation of an environmental impact statement (EIS). Following the issuance of a revised Final EIS in 2025, several environmental and tribal groups, as well as individual Apache plaintiffs, challenged the exchange. Their claims spanned the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), the Religious Freedom Restoration Act (RFRA), and the Free Exercise Clause, alleging procedural and substantive deficiencies.Previously, the United States District Court for the District of Arizona denied the plaintiffs’ motions for a preliminary injunction, finding that they had not demonstrated a likelihood of success on any claims relating to the appraisal process, NEPA, consultation, or the National Forest Management Act. A separate group of Apache plaintiffs brought similar claims, including religious liberty challenges, which were also denied—particularly in light of circuit precedent established in Apache Stronghold v. United States. All plaintiff groups appealed and sought further injunctive relief pending appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial for abuse of discretion and affirmed. The court held that plaintiffs had standing and their claims were justiciable, but that none of their arguments were likely to succeed on the merits or raised serious questions. The court specifically found the appraisals and environmental review sufficient, the agency’s tribal consultation adequate, and the religious liberty claims foreclosed by circuit precedent. The denial of a preliminary injunction was affirmed, and all related motions for injunctive relief were denied as moot. View "ARIZONA MINING REFORM COALITION V. UNITED STATES FOREST SERVICE" on Justia Law

A group composed of individuals, nonprofits, and businesses in Montana challenged the enforcement of a newly enacted state law, H.B. 359, which prohibited “drag story hours” and “sexually oriented performances” in various locations, including state-funded schools, libraries, public property, and certain businesses. The law imposed criminal, civil, and professional penalties, and also created a private right of action against violators. Plaintiffs contended that the statute violated their rights to freedom of speech under the First Amendment and to due process under the Fifth Amendment, both on its face and as applied to their speech.In the United States District Court for the District of Montana, the plaintiffs moved for a preliminary injunction to prevent state officials from enforcing H.B. 359 while their challenge was pending. The district court found that the plaintiffs had standing, as at least one plaintiff demonstrated a credible threat of enforcement and self-censorship for each challenged provision. The district court then applied the Winter v. Natural Resources Defense Council standard for preliminary injunctions and concluded that plaintiffs were likely to succeed on the merits of their First Amendment claims. The court found H.B. 359 to be a content-based and viewpoint-based restriction on expressive activity that failed strict scrutiny, and further determined the statute was unconstitutionally vague. The court granted a preliminary injunction, barring enforcement of H.B. 359 by the state defendants.The United States Court of Appeals for the Ninth Circuit reviewed the appeal by the Montana Attorney General and Superintendent of Public Instruction. The Ninth Circuit affirmed the district court’s order, holding that the plaintiffs had standing and that the district court did not abuse its discretion. The appellate court held that both the drag-story-hour and sexually-oriented-performance provisions are content-based restrictions on protected expressive activity and are not narrowly tailored to a compelling governmental interest. Accordingly, the preliminary injunction against enforcement of H.B. 359 was affirmed. View "IMPERIAL SOVEREIGN COURT OF THE STATE OF MONTANA V. KNUDSEN" on Justia Law

A national trade association representing large online businesses challenged a recently enacted California statute designed to protect minors’ privacy and well-being online. The law imposes specific requirements on businesses whose online services are likely to be accessed by children under eighteen, including obligations regarding data use, age estimation, and restrictions on certain user interface designs known as “dark patterns.” Before the law took effect, the association brought suit in the United States District Court for the Northern District of California, arguing that several provisions were unconstitutional on First Amendment and vagueness grounds, and sought a preliminary injunction to prevent enforcement.The district court initially enjoined the entire statute, finding the association was likely to succeed on its facial First Amendment challenge. On the State’s appeal, the United States Court of Appeals for the Ninth Circuit vacated most of the injunction, affirming only as to a specific requirement regarding Data Protection Impact Assessments and related inseverable provisions, and remanded for the district court to analyze the association’s other facial challenges and the issue of severability under the Supreme Court’s clarified standards in Moody v. NetChoice, LLC. On remand, the district court again enjoined the entire statute and, in the alternative, seven specific provisions.On further appeal, the United States Court of Appeals for the Ninth Circuit held that the association did not meet its burden for a facial challenge to the law’s coverage definition or its age estimation requirement, vacating the injunction as to those. However, the court affirmed the preliminary injunction as to the law’s data use and dark patterns restrictions on vagueness grounds, finding the provisions failed to clearly delineate prohibited conduct. The court vacated the injunction as to the statute’s remainder and remanded for further proceedings on severability. View "NETCHOICE, LLC V. BONTA" on Justia Law

The case concerns a habeas corpus petition filed by an individual convicted and sentenced to death for the willful, deliberate, and premeditated murder of Janine Lee in California in 1993. The petitioner had worked with the victim and, after planning the crime, killed her for financial gain and subsequently attempted to cash her checks. Forensic evidence and the petitioner’s confession corroborated his involvement, including details about the killing, use of martial arts training, and subsequent events. Expert testimony at trial highlighted the petitioner’s mental health issues, drug use, and troubled social history, but the jury found him guilty and sentenced him to death.Following his conviction and sentencing, the California Supreme Court affirmed the judgment on direct appeal and summarily denied habeas relief. The United States District Court for the Central District of California denied the federal habeas petition under 28 U.S.C. § 2254, but granted a certificate of appealability for claims of ineffective assistance of counsel during the penalty phase. The petitioner sought to expand the certificate to include additional claims related to competency and juror bias.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of habeas relief. Applying AEDPA deference, the Ninth Circuit held that the California Supreme Court could have reasonably determined that the petitioner failed to make a prima facie case for relief on all penalty-phase ineffective assistance subclaims, including alleged failures to investigate, prepare witnesses, and rebut aggravating evidence. The court also rejected cumulative error and competency claims, and denied a certificate of appealability for juror bias. The panel granted a certificate for one penalty-phase competency subclaim but affirmed its denial. The district court’s denial of habeas corpus relief was affirmed. View "COMBS V. BROOMFIELD" on Justia Law

Two blind individuals, after enrolling at a community college in Los Angeles, were approved for disability accommodations, including accessible course materials and technology. Despite these approvals, they faced repeated barriers in accessing required textbooks, online platforms, library resources, and other educational tools. They also experienced difficulties in receiving their approved accommodations, such as accessible test-taking and note-taking support. These obstacles led to their inability to participate fully in their courses and, in one case, being steered away from certain classes due to their disability.After a jury trial in the United States District Court for the Central District of California, the jury found the college district liable on multiple counts and awarded damages for intentional violations of Title II of the Americans with Disabilities Act (ADA). The district court, however, reduced the damages to only out-of-pocket expenses, concluding that the jury’s award could only be for emotional distress or lost educational opportunities—both of which it believed were not recoverable. The district court also issued injunctive relief. The plaintiffs appealed the reduction of damages.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that, under Supreme Court precedent, emotional distress damages are not available under Title II of the ADA because the statute’s remedies are coextensive with those of the Rehabilitation Act and Title VI of the Civil Rights Act, which do not permit such damages. However, the Ninth Circuit concluded that plaintiffs may recover compensatory damages for loss of educational opportunities resulting from ADA violations. The court found that the jury’s award was supported by evidence and the instructions given. The Ninth Circuit reversed the district court’s remittitur, vacated its judgment as to damages, and remanded with instructions to reinstate the original jury awards. View "PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT" on Justia Law