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

Mariusz Klin, the lead plaintiff, purchased Cloudera stock between its initial public offering (IPO) and a subsequent price drop following the company's announcement of negative quarterly earnings. Klin alleged that Cloudera, Inc. and its officers and directors made materially false and misleading statements and omissions about the technical capabilities of its products, particularly regarding their "cloud-native" nature.The United States District Court for the Northern District of California dismissed Klin's first amended complaint for failure to state a claim, noting that Klin did not adequately explain what "cloud-native" meant at the time the statements were made. The court allowed Klin to file a second amended complaint, instructing him to provide a contemporaneous definition of "cloud-native" and explain why Cloudera's statements were false when made. Klin's second amended complaint was also dismissed for failing to meet the heightened pleading standards required for fraud claims, as it did not provide sufficient factual support for the definitions of the cloud-related terms.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that Klin did not adequately plead the falsity of Cloudera's statements with the particularity required under Rule 9(b) and the Private Securities Litigation Reform Act (PSLRA). The court noted that Klin's definitions of cloud-related terms lacked evidentiary support and that the cited blog post did not substantiate his claims. Additionally, the court found that Klin's reliance on later statements and product developments did not establish the falsity of the earlier statements.The Ninth Circuit also affirmed the district court's decision to deny further leave to amend, concluding that additional amendments would be futile. Klin had not identified specific facts that could remedy the deficiencies in his complaint, and the court saw no reason to believe that another amendment would succeed. The court's decision to dismiss the case with prejudice was upheld. View "IN RE: MARIUSZ KLIN V. CLOUDERA, INC." on Justia Law

Charles Porter, a Yosemite National Park employee, was charged with various sexual assault offenses after attempting to anally rape T.D., another male park employee, in April 2020. T.D. testified that Porter, heavily intoxicated, forced himself on T.D. in his cabin. Neighbors corroborated T.D.'s account. Porter claimed T.D. was the aggressor. The district court allowed testimony from Porter’s ex-girlfriend, A.H., under Federal Rule of Evidence 413, which permits evidence of prior sexual assaults. A.H. testified that Porter had previously engaged in nonconsensual sex with her.The United States District Court for the Eastern District of California admitted A.H.'s testimony after evaluating its probative value against potential prejudice under Rule 403. The jury found Porter guilty on all counts, and he was sentenced to 148 months in prison. Porter appealed, arguing that Rule 413 violates the Fifth Amendment’s Due Process Clause by allowing propensity evidence.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Rule 413 is constitutional, referencing its decision in United States v. Lemay, which upheld the analogous Rule 414 for child molestation cases. The court emphasized that Rule 413, like Rule 414, is subject to Rule 403, which allows district courts to exclude unduly prejudicial evidence. The court found that the district court had properly applied Rule 403 and provided appropriate limiting instructions to the jury regarding A.H.'s testimony.The Ninth Circuit affirmed Porter’s conviction, concluding that the admission of A.H.'s testimony under Rule 413 did not violate due process. View "U.S. v. Porter" on Justia Law

The case involves a child-pornography investigation initiated by two CyberTipline Reports forwarded to the FBI by the National Center for Missing and Exploited Children (NCMEC). Special Agent Emily Steele viewed two images from Facebook without a warrant, one of which matched a previously reported child exploitation image. This led to a search warrant for Aaron Holmes's residence, where incriminating statements and numerous illicit images were found on his cellphone. Holmes moved to suppress this evidence, arguing it was obtained unlawfully.The United States District Court for the District of Arizona denied Holmes's motion to suppress, concluding that the good-faith exception applied to Agent Steele’s viewing of the hash-matched image and that the inevitable-discovery exception applied because Agent Rose would have inevitably discovered the same evidence through routine procedures.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the good-faith exception did not apply because the existing precedent was contradictory and only plausibly supported Agent Steele’s warrantless viewing of the images. The court also rejected the inevitable-discovery exception, finding that the Government failed to prove that Agent Rose would have inevitably discovered the same evidence through lawful means. The court noted that Agent Rose’s investigation was not as urgent or thorough as Agent Steele’s, and there was no certainty that Holmes would have been present during a hypothetical search by Agent Rose. Consequently, the Ninth Circuit reversed the district court’s denial of Holmes’s motion to suppress and remanded the case for further proceedings. View "U.S. v. Holmes" on Justia Law

The petitioner, Jose Ernesto Aleman-Belloso, a native and citizen of El Salvador, sought review of a decision by the Board of Immigration Appeals (BIA) that upheld an Immigration Judge's (IJ) denial of his claims for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). Aleman, an influential lay minister in his church, was approached by members of the FMLN, a political party in El Salvador, to use his influence to garner support for the party. After refusing their proposition, Aleman was attacked by masked gunmen who threatened him and demanded he leave town. Aleman fled to the United States shortly after.The IJ found Aleman’s testimony credible and acknowledged that he was tortured by the FMLN. However, the IJ concluded that Aleman failed to establish a nexus between the harm he suffered and any protected grounds, thus denying his claims for asylum and withholding of removal. The IJ also denied CAT relief, finding it unlikely that Aleman would be tortured again in the future. The BIA affirmed the IJ's decision, agreeing that Aleman did not demonstrate a sufficient nexus between the persecution and his religious beliefs, political opinion, or membership in a particular social group.The United States Court of Appeals for the Ninth Circuit reviewed the case and found that the BIA erred in its conclusions. The court held that substantial evidence did not support the BIA’s finding of no nexus between the persecution Aleman suffered and his political opinion or membership in a particular social group. The court noted that Aleman’s refusal to support the FMLN was a political opinion and that the FMLN attacked him because of this opinion. Additionally, the court found that the BIA mischaracterized Aleman’s proposed social group and improperly rejected it as circularly defined. The court also concluded that the BIA failed to consider probative evidence regarding government involvement in Aleman’s past torture and the FMLN’s continued power in El Salvador.The Ninth Circuit granted Aleman’s petition for review, remanding the case to the BIA for further proceedings consistent with its opinion. The court instructed the BIA to reconsider Aleman’s claims for asylum, withholding of removal, and CAT relief, taking into account the correct characterization of his social group and the evidence of government involvement in his persecution. View "ALEMAN-BELLOSO V. GARLAND" on Justia Law

Grand Canyon University (GCU), a private university in Arizona, applied to the U.S. Department of Education to be recognized as a nonprofit institution under the Higher Education Act of 1965 (HEA). The Department denied GCU’s application, despite GCU having obtained 26 U.S.C. § 501(c)(3) recognition from the IRS as a tax-exempt organization. The Department concluded that GCU did not meet the operational test’s requirement that both the primary activities of the organization and its stream of revenue benefit the nonprofit itself.The U.S. District Court for the District of Arizona granted summary judgment in favor of the Department, upholding the denial of GCU’s application. The court found that the Department’s decision was not arbitrary and capricious or contrary to law. GCU appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that the Department applied the wrong legal standards in evaluating GCU’s application. Specifically, the Department incorrectly relied on IRS regulations that impose requirements beyond those of the HEA. The correct HEA standards required the Department to determine whether GCU was owned and operated by a nonprofit corporation and whether GCU satisfied the no-inurement requirement. The Department’s failure to apply these correct legal standards necessitated that its decision be set aside.The Ninth Circuit reversed the judgment of the district court and remanded the case with instructions to set aside the Department’s denials and to remand to the Department for further proceedings consistent with the correct legal standards under the HEA. View "GRAND CANYON UNIVERSITY V. CARDONA" on Justia Law

A class of over 500,000 federal student loan borrowers sued the U.S. Department of Education for failing to process their borrower defense (BD) applications. The Department and the plaintiffs reached a settlement, which included automatic debt forgiveness for certain borrowers and streamlined adjudication for others. Three for-profit universities (the Schools) listed in the settlement as having substantial misconduct intervened, claiming reputational harm.The U.S. District Court for the Northern District of California approved the settlement and denied the Schools' motion to intervene as of right but allowed them to object to the settlement. The Schools appealed, arguing that the settlement caused them reputational and financial harm and interfered with their procedural rights.The United States Court of Appeals for the Ninth Circuit held that the Schools had Article III standing due to alleged reputational harm but lacked prudential standing to challenge the settlement because they did not demonstrate formal legal prejudice. The court found that the dispute between the plaintiffs and the Department was not moot, as the Department's voluntary cessation of issuing pro forma denials did not render the case moot. The court also affirmed the district court's denial of the Schools' motion to intervene as of right, concluding that the Schools did not have a significantly protectable interest and failed to show prejudice from the denial of intervention as of right.The Ninth Circuit dismissed the appeal in part and affirmed the district court's denial of intervention as of right. View "Sweet v. Everglades College, Inc." on Justia Law

Several states challenged Executive Order 14026, which mandated a $15 minimum wage for federal contractors, and the Department of Labor (DOL) rule implementing it. The states argued that the executive order and the DOL rule violated the Federal Property and Administrative Services Act (FPASA) and the major questions doctrine, and that the DOL rule violated the Administrative Procedure Act (APA).The United States District Court for the District of Arizona dismissed the states' complaint and denied their request for a preliminary injunction. The district court concluded that the wage mandate did not violate the FPASA, the major questions doctrine did not apply, and the rule was not subject to arbitrary-or-capricious review under the APA because the DOL had to adopt the policy by executive order.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's dismissal of the complaint, vacated the denial of the preliminary injunction, and remanded for further proceedings. The Ninth Circuit held that the minimum wage mandate exceeded the authority granted to the President and DOL under the FPASA because the FPASA’s purpose statement does not authorize the President to impose a wage mandate without other operative language in the FPASA. The court also held that the major questions doctrine did not apply because the executive order was not a transformative expansion of authority. Finally, the court found that the DOL acted arbitrarily or capriciously by failing to consider alternatives to the $15 per hour minimum wage mandate, thus violating the APA. View "STATE OF NEBRASKA V. SU" on Justia Law

Dzung Ahn Pham, a former licensed physician, sought to withdraw his guilty plea to conspiracy to distribute controlled substances in violation of the Controlled Substances Act (CSA). Pham admitted in his plea agreement to conspiring with a pharmacist to prescribe and distribute over 150,000 narcotic pills, knowing he was doing so outside the usual course of professional medical practice and without a legitimate medical purpose. He later argued that his plea was not knowing and voluntary, citing the Supreme Court's decision in Ruan v. United States, which he claimed required the government to prove that he knew he was not authorized under the CSA to issue the prescriptions.The United States District Court for the Central District of California denied Pham's motion to withdraw his guilty plea. The court held that the indictment, plea agreement, and colloquy all incorporated the elements of the offense, including the standard of guilty knowledge required for conviction. Pham's admissions during the plea process were found to be consistent with the requirements set forth in Ruan.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that Pham's admissions to knowingly and intentionally issuing prescriptions outside the usual course of professional medical practice and without a legitimate medical purpose provided the requisite proof that he acted in an unauthorized manner. Therefore, Pham failed to demonstrate that his guilty plea was unknowing or involuntary, and the district court did not err in denying his motion to withdraw the plea. The Ninth Circuit concluded that the plea agreement and colloquy met the standards established by Ruan, and Pham's appeal was dismissed. View "USA V. PHAM" on Justia Law

Consuelo Griselda Nerio Mejia challenged the denial of her disability benefits by the Social Security Administration (SSA). After an administrative law judge (ALJ) denied her application, concluding that despite her severe impairments, she could perform other jobs available in the national economy, Nerio Mejia filed a civil suit. She raised three objections to the ALJ's decision, but the district court only addressed her claim that the ALJ improperly rejected her symptomology testimony, finding that the ALJ failed to provide clear and convincing reasons for doing so. The court reversed the ALJ's decision and remanded the case to the SSA for further proceedings.The United States District Court for the Central District of California found that the SSA's position was not substantially justified, making Nerio Mejia eligible for attorneys' fees under the Equal Access to Justice Act (EAJA). However, the district court reduced the fee award, excluding time spent on two additional issues that the court did not address, citing the Ninth Circuit's decision in Hardisty v. Astrue. The court concluded that fees for work on issues not decided by the court were not compensable under the EAJA.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's order reducing the fee award. The Ninth Circuit held that the district court misapplied Hardisty, which did not address the compensability of fees for undecided issues. The appellate court found that the district court's ruling was contrary to the Supreme Court's decision in Hensley v. Eckerhart and the Ninth Circuit's en banc decision in Ibrahim v. United States Department of Homeland Security. These cases establish that a fully compensatory fee should be awarded when a plaintiff achieves excellent results, even if some issues were not decided. The Ninth Circuit remanded the case with instructions to award the full amount of fees requested by Nerio Mejia. View "MEJIA V. O'MALLEY" on Justia Law

An Arizona state inmate, Michael Ray Fuqua, who identifies as a Christian-Israelite, requested a religious dietary accommodation to observe Passover and the Feast of Unleavened Bread. The prison chaplain, Jeffrey Lind, denied this request, arguing that Fuqua did not substantiate his request with appropriate documentation and that his beliefs were theologically inconsistent. Fuqua claimed that this denial forced him to either starve or spend significant money on commissary food, causing him physical and financial hardship.The United States District Court for the District of Arizona granted summary judgment in favor of Lind on Fuqua’s First Amendment Free Exercise, Fourteenth Amendment Equal Protection, and Religious Land Use and Institutionalized Persons Act (RLUIPA) claims. The court found that Fuqua failed to show a substantial burden on his religious exercise and that Lind had legitimate reasons for denying the request. The court also held that RLUIPA only authorizes equitable relief, which was moot in Fuqua’s case.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Fuqua’s First Amendment and Equal Protection claims, finding that a reasonable trier of fact could conclude that Lind’s denial was based on his own theological assessment rather than a neutral procedural rule. This could constitute a substantial burden on Fuqua’s religious exercise and intentional discrimination. However, the court affirmed the summary judgment on the RLUIPA claim, citing the Ninth Circuit’s decision in Wood v. Yordy, which precludes suits seeking monetary damages under RLUIPA against state officers, and Fuqua’s equitable claims were moot. The case was remanded for further proceedings consistent with this opinion. View "FUQUA V. RAAK" on Justia Law