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

Victor Grandy was convicted by a jury in 1993 for distributing at least fifty grams of crack cocaine, violating 21 U.S.C. § 841(a)(1). He was sentenced to life imprisonment and a ten-year term of supervised release, as required by the statute at the time. After serving over twenty-six years in prison, Grandy’s sentence was reduced in 2019 under the First Step Act, and he began his supervised release. During supervised release, Grandy demonstrated successful reintegration, maintaining stable employment, volunteering, and pursuing a flourishing art career. However, the conditions of supervised release limited his ability to travel for art shows. In February 2025, Grandy moved for early termination of supervised release, citing his exemplary conduct and professional burdens.The United States District Court for the Central District of California denied Grandy’s motion. The court reasoned that the mandatory minimum term of supervised release imposed under 21 U.S.C. § 841(b)(1) precluded early termination. It further determined Grandy had not shown extraordinary circumstances warranting early termination, relying on extrarecord sources: a 2022 U.S. Sentencing Commission recidivism study and an outdated Administrative Office of the U.S. Courts’ Guide. The court misinterpreted statistics from the study and applied an obsolete nine-factor test, concluding Grandy’s ongoing success justified continued supervision.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that 21 U.S.C. § 841(b)(1) does not prohibit early termination of supervised release under 18 U.S.C. § 3583(e)(1), as the government conceded. The Ninth Circuit found the district court abused its discretion by misinterpreting extrarecord evidence, relying on outdated guidance, and treating Grandy’s success as a reason for continued supervision. The court reversed the denial of Grandy’s motion and remanded for further proceedings, declining to reassign the case to a different judge. View "USA V. GRANDY" on Justia Law

A Sedona resident, who has obsessive-compulsive disorder, often sleeps in her car because her disability prevents her from entering her apartment. The City of Sedona has a criminal ordinance prohibiting sleeping in a vehicle on public or private property. The resident was twice warned by police for sleeping in her car and requested reasonable accommodation under the Americans with Disabilities Act (ADA) to exempt her from enforcement of this ordinance. The city denied her requests, and her landlord threatened not to renew her lease if she continued sleeping in her car. She alleges that the city’s actions caused her emotional distress and loss of income, and she continues to sleep in her car several times a week.The United States District Court for the District of Arizona dismissed her claims for lack of standing, finding that the prior police warnings were insufficient to support a specific threat of prosecution and that she failed to allege a history of enforcement against similarly situated individuals. The district court addressed only her standing to seek injunctive relief, despite her claims for damages as well. Her requests to amend her complaint were denied, and she appealed.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s dismissal. The Ninth Circuit held that she had Article III standing to bring an ADA claim for both damages and injunctive relief, based on the city’s denial of her request for accommodation and a credible threat of future enforcement. The court further held that Title II of the ADA applies to requests for reasonable accommodation to comply with municipal criminal ordinances. The ADA claim was remanded for further proceedings, allowing her to amend her complaint, while the dismissal of her Eighth Amendment claim was affirmed. View "BERAM V. CITY OF SEDONA" on Justia Law

Five individuals, who were either peaceful protesters or independent journalists, attended demonstrations at the U.S. Immigration and Customs Enforcement facility in Portland, Oregon. During these events, they were exposed to tear gas and pepper balls used by federal agents to disperse crowds. The protests involved both peaceful activities and significant unrest, including vandalism, blocking entrances, and attacks on law enforcement. The plaintiffs claimed that federal agents specifically targeted them in retaliation for exercising their First Amendment rights.The plaintiffs filed suit in the United States District Court for the District of Oregon against federal officials and the Department of Homeland Security. After discovery and an evidentiary hearing, the District Court issued a preliminary injunction restricting the use of non-lethal munitions to situations involving an imminent threat of physical harm, prohibiting their use on certain parts of the body, imposing limits on pepper spray, and requiring redesign of agent uniforms for better identification. Additionally, the District Court provisionally certified a class of all individuals who had protested or reported on DHS activities at the Portland ICE facility. The government’s motion to stay the injunction pending appeal was denied by the District Court but granted by the Ninth Circuit.On appeal, the United States Court of Appeals for the Ninth Circuit vacated both the preliminary injunction and the provisional class certification. The court held that the plaintiffs were not likely to succeed on the merits of their First Amendment retaliation claim, as law enforcement may use non-lethal force to clear crowds and restore order without facing an imminent threat of physical harm. The record did not support claims of an unwritten policy or intent to retaliate against First Amendment activity. The court also found the injunction overbroad and unworkable, and the class failed to meet Rule 23’s commonality and indivisible remedy requirements. The preliminary injunction and class certification were vacated. View "DICKINSON V. TRUMP" on Justia Law

Several tenants of an apartment complex located across the street from a federal Immigration and Customs Enforcement (ICE) facility in Portland, Oregon, claimed harm from exposure to tear gas used by federal law enforcement officers to disperse disruptive crowds during demonstrations. The plaintiffs, including individuals and entities associated with the apartment complex, argued that the government’s deployment of tear gas infringed their substantive-due-process rights under the Fifth Amendment.The United States District Court for the District of Oregon granted a preliminary injunction, enjoining several federal agencies from using tear gas for crowd control outside the ICE facility. The district court found that the plaintiffs were likely to succeed on the merits of their substantive-due-process claim and determined that the government’s actions could violate a constitutional right to bodily integrity.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. Applying de novo review to the underlying legal issues, the Ninth Circuit reaffirmed its prior stay of the injunction and concluded that the plaintiffs lacked a substantive-due-process right to be free from incidental exposure to tear gas used for non-lethal crowd control. The court held that such a right is not deeply rooted in the nation’s history and tradition nor implicit in the concept of ordered liberty, as required by Supreme Court precedents, including Washington v. Glucksberg and Dobbs v. Jackson Women’s Health Organization. The panel further clarified that a substantive-due-process challenge to executive action requires both conscience-shocking conduct and deprivation of a historically rooted right, rejecting the plaintiffs’ argument that only the shocks-the-conscience standard should apply. Accordingly, the Ninth Circuit vacated the district court’s preliminary injunction. View "REACH COMMUNITY DEVELOPMENT V. UNITED STATES DEPARTMENT OF HOMELAND SECURITY" on Justia Law

Eight former employees of a space technology company were dismissed shortly after they circulated an open letter to management expressing concerns about workplace conduct they believed constituted sexual harassment. The letter specifically criticized the company founder’s posts on social media, which the plaintiffs alleged created a hostile work environment. After their termination, the plaintiffs filed suit asserting claims under California law, including hostile work environment sexual harassment, gender discrimination, failure to prevent discrimination and retaliation, and retaliatory termination for opposing alleged sexual harassment.The plaintiffs originally brought their case in state court. The defendant responded by filing an answer and then removed the case to the United States District Court for the Central District of California, asserting diversity jurisdiction. Once in federal court, the defendant moved to compel arbitration, citing arbitration agreements signed by each plaintiff as part of their employment contracts. The defendant argued that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) did not exempt the plaintiffs’ claims from arbitration, contending that the statute required “adequately alleged” sexual harassment—allegations sufficient to survive a federal motion to dismiss.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Ninth Circuit held that the EFAA exempts the plaintiffs’ case from arbitration. The court ruled that the EFAA’s definition of a “sexual harassment dispute” is satisfied when the complaint asserts conduct alleged to amount to sexual harassment, without requiring allegations sufficient to survive a motion to dismiss. The court affirmed the district court’s order, concluding that the plaintiffs properly invoked the EFAA and that their case “relates to” a sexual harassment dispute. Thus, the arbitration agreements are not enforceable for this case. View "HOLLAND-THIELEN v. SPACEX" on Justia Law

Several chambers of commerce and business associations challenged two California statutes—the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261)—on First Amendment grounds. SB 253 requires large companies to annually disclose greenhouse gas emissions in three categories: Scope 1 (direct emissions from owned or controlled sources), Scope 2 (indirect emissions from purchased energy), and Scope 3 (indirect emissions throughout the company’s value chain, including suppliers and customers). SB 261 mandates covered companies to publicly disclose climate-related financial risk information, including assessments about their exposure to climate change and related business impacts.The United States District Court for the Central District of California denied the plaintiffs’ motion for a preliminary injunction. The court determined that both SB 253 and SB 261 regulate commercial speech and thus are not subject to strict scrutiny. Applying intermediate scrutiny and, for SB 253, the more deferential Zauderer standard, the district court found that both statutes reasonably advance California’s substantial interests such as providing investors with information and reducing emissions. It concluded that the plaintiffs were unlikely to succeed on their First Amendment claims and failed to meet the other requirements for preliminary relief.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of injunctive relief. The Ninth Circuit affirmed the denial as to SB 253’s Scope 1 and Scope 2 disclosure requirements, holding these provisions regulate commercial speech and withstand intermediate scrutiny. However, it reversed the denial as to SB 253’s Scope 3 disclosure requirement and SB 261 in its entirety. The court found that Scope 3 disclosures and SB 261 compel noncommercial speech subject to strict scrutiny, which the State could not satisfy. The case was remanded for the district court to determine whether SB 253’s Scope 3 disclosure provisions are severable. View "UNITED STATES OF AMERICA CHAMBER OF COMMERCE V. SANCHEZ" on Justia Law

A former member of the Los Angeles County Board of Supervisors was convicted for conspiracy, federal program bribery, and honest services mail and wire fraud. The case centered on a scheme where the then-Dean of the University of Southern California’s School of Social Work helped channel a $100,000 donation of university funds to a nonprofit employing the supervisor’s son. In exchange, the supervisor voted in favor of a county contract for telehealth services with USC. The evidence showed the supervisor valued the indirect transfer of funds for his son’s benefit, especially after previous attempts to provide direct funding raised concerns about nepotism.The United States District Court for the Central District of California presided over a sixteen-day trial. The jury convicted the supervisor on counts specifically related to the funneling of the $100,000 payment, while acquitting him on other counts tied to his son’s admission, scholarship, or professorship at USC. Following conviction, the supervisor appealed, challenging the Government’s theory of fraud and bribery, the legal validity of the “thing of value,” and the sufficiency of evidence for materiality and intent. He also contested the jury instructions and raised Batson challenges regarding the exclusion of Black female jurors.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court held that the funneling of $100,000 through USC for the son’s benefit was a “thing of value” sufficient to support convictions for honest services fraud and federal program bribery. The court found the evidence of intent and materiality sufficient, determined there was no error in the jury instructions, and rejected the extension of Batson to intersectional challenges. The convictions for conspiracy, federal program bribery, and honest services fraud were affirmed. View "USA V. RIDLEY-THOMAS" on Justia Law

The defendant was accused of participating in a plan to attack a public event in Garland, Texas, which was targeted for its association with controversial depictions of the Prophet Muhammad. The attack was carried out by two individuals, Simpson and Soofi, who were killed during the incident. Investigators uncovered evidence of the defendant’s close association with the attackers, his consumption of extremist propaganda, and his involvement in firearms training and procurement. The government argued that the defendant, along with Simpson and Soofi, conspired to provide material support to ISIS, specifically as “personnel” or by providing “services” in the form of the attack.After a trial in the United States District Court for the District of Arizona, a jury convicted the defendant on all counts, including conspiracy to provide material support to a foreign terrorist organization in violation of 18 U.S.C. § 2339B (Count 5). The district court sentenced him to 360 months’ imprisonment. Post-trial, the defendant filed motions for acquittal and new trials, including arguments based on Brady violations, but relief was denied for Count 5. The government dismissed another count, and the district court resentenced him to the same term. The defendant timely appealed his conviction on Count 5, arguing insufficient evidence to support the jury’s finding.The United States Court of Appeals for the Ninth Circuit reviewed the sufficiency of the evidence under the Jackson v. Virginia standard, regardless of whether the claim was preserved below. The court held that the government failed to present sufficient evidence that the defendant intended to join a conspiracy in which material support would be provided to ISIS, either as “personnel” acting under ISIS’s direction or as “services” beyond independent advocacy. The court reversed the conviction on Count 5, remanded for entry of acquittal and resentencing, and affirmed the district court’s rulings on all other issues. View "USA V. ABDUL KAREEM" on Justia Law

A mother and son, both debtors, repeatedly filed for bankruptcy under Chapter 13 after a lender, Milestone Financial, LLC, foreclosed on a property for which they had not made any mortgage payments. After foreclosure, Milestone sought to evict them, but local eviction moratoria delayed the process. As the unlawful detainer action approached trial, both debtors filed new Chapter 13 petitions, which triggered an automatic stay and halted eviction. Their bankruptcy petitions were incomplete, lacking required schedules and documents. Despite receiving an extension to file the missing documents, the debtors did not comply, but instead filed motions for voluntary dismissal under 11 U.S.C. § 1307(b) on the final day of the extension.The United States Bankruptcy Court for the Northern District of California dismissed both cases for failure to comply with its order to file the missing documents, rather than on the debtors’ request for voluntary dismissal. It also imposed a one-year bar prohibiting the debtors from refiling for bankruptcy. The debtors’ motions for reconsideration were denied, and they appealed. The Bankruptcy Appellate Panel (BAP) affirmed the imposition of the one-year refiling bar but certified the question of the length of such a bar for direct appeal to the United States Court of Appeals for the Ninth Circuit.The United States Court of Appeals for the Ninth Circuit held that under 11 U.S.C. § 1307(b), a debtor has an absolute right to voluntarily dismiss a Chapter 13 case, even if the case was filed in bad faith, and the bankruptcy court erred by dismissing for failure to comply with a court order instead of granting the voluntary dismissal request. However, the Ninth Circuit affirmed the one-year refiling bar, concluding that the bankruptcy court had authority under 11 U.S.C. § 349(a) to impose such a sanction for cause, and that the statutory 180-day bar in § 109(g) does not limit the court’s authority to impose a longer bar for repeated bad faith filings. View "SRINIVASAN V. MILESTONE FINANCIAL, LLC" on Justia Law

During a protest at San Jose City Hall, the plaintiff attended as a peaceful participant. At one point in the evening, after some protestors threw bottles and objects at the police, an officer equipped with a 40mm projectile impact weapon responded by firing into the crowd. The plaintiff, who did not throw anything or engage with the police, was struck behind the knee by a foam baton round and subsequently developed a pulmonary embolism as a result of his injury.After these events, the plaintiff filed suit in the United States District Court for the Northern District of California against the officer and the City of San Jose, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and California’s Bane Act, as well as common law claims. The case proceeded to trial, where the plaintiff argued that the officer fired indiscriminately into the crowd rather than targeting a specific threat. The jury found in favor of the plaintiff on all claims against the officer, awarding damages, and specifically found that the officer fired indiscriminately. The district court denied the officer’s post-verdict motion for judgment as a matter of law on the Fourth Amendment and Bane Act claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court concluded that the officer’s actions constituted a seizure and that the use of force was excessive, thus violating the plaintiff’s Fourth Amendment rights. However, the court held that the law was not clearly established for purposes of qualified immunity because prior precedent, particularly Nelson v. City of Davis, was materially distinguishable from the circumstances present here. As a result, the Ninth Circuit reversed the district court’s denial of qualified immunity on the Fourth Amendment claim, vacated the award of attorneys’ fees, and remanded for recalculation pending resolution of the state law claim, which was certified to the California Supreme Court. View "JOHNSON V. ADGAR" on Justia Law