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

California enacted the No Vigilantes Act, which, among other things, requires any non-uniformed federal law enforcement officer operating in the state to visibly display identification showing their agency and either a name or badge number while performing enforcement duties. This requirement, codified at California Penal Code § 13654, applies broadly to federal officers, subject to narrow exceptions, and provides for criminal penalties for willful violations. The Act also allows agencies to avoid these requirements by publicly posting a written identification policy that complies with the statute.After the Act was passed, the United States filed a lawsuit in the United States District Court for the Central District of California, challenging the constitutionality of the identification requirement before it had been enforced. The United States argued that the law violated the Supremacy Clause by directly regulating federal law enforcement operations. The district court denied the United States’ request for a preliminary injunction against enforcement of the identification requirement, finding the government had not shown that California’s law interfered with or controlled federal operations to a degree that would render it unconstitutional. The district court did, however, grant partial relief under a different statute, and ruled that the United States lacked standing to challenge other provisions.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s denial of a preliminary injunction. The Ninth Circuit concluded that the United States was certain to succeed on its Supremacy Clause claim because the Act directly regulated federal operations without congressional authorization, in violation of intergovernmental immunity. The court held that no set of circumstances existed under which the challenged requirement would be valid, and that the other factors for preliminary injunctive relief also favored the United States. The Ninth Circuit ordered the district court to enter a preliminary injunction barring enforcement of the identification requirement against the United States, its agencies, and officers. View "USA V. STATE OF CALIFORNIA" on Justia Law

Dylan Youngblood was arrested in Kalispell, Montana, in September 2023 on an outstanding felony warrant. During the arrest, officers found fentanyl pills on his person and located two pistols, drug paraphernalia, and suspected methamphetamine in his car. Youngblood admitted ownership of one pistol and to having used fentanyl earlier that day. He was indicted for possessing a firearm while being an unlawful user of, and addicted to, a controlled substance, in violation of 18 U.S.C. § 922(g)(3).In the United States District Court for the District of Montana, Youngblood moved to dismiss the indictment, arguing that § 922(g)(3) was unconstitutional both on its face and as applied to him. The district court denied the motion, applying the Second Amendment framework from New York State Rifle & Pistol Ass’n v. Bruen, and found that while Youngblood’s conduct fell within the Second Amendment’s text, the statute’s application to frequent users of methamphetamine and fentanyl was consistent with a historical tradition of temporarily disarming intoxicated individuals. The district court concluded that the statute was both facially and as-applied constitutional. Youngblood then entered a conditional guilty plea, preserving his right to appeal the denial of his motion.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that its prior decision in United States v. Stennerson, which upheld the facial constitutionality of § 922(g)(3), remained binding even after the Supreme Court’s decision in United States v. Hemani, which addressed only an as-applied challenge. The Ninth Circuit also found that Youngblood waived his as-applied challenge by failing to argue it specifically and distinctly in his opening brief. The court affirmed Youngblood’s conviction. View "USA V. YOUNGBLOOD" on Justia Law

The case concerns a challenge by an environmental organization to a U.S. Forest Service project in the Idaho Panhandle National Forest known as the Hanna Flats Good Neighbor Authority Project. The Project was intended to manage vegetation and reduce wildfire risk, and involved the use and closure of several miles of road within an area known as the Priest Bears Outside Recovery Zone (BORZ), which is important grizzly bear habitat. After the Project was approved, it was discovered that the total miles of road in the Priest BORZ exceeded the baseline established in 2011 by the Access Amendments to the Forest Plan, which limited road construction to protect bear habitat. This overage was due to roads that existed before 2011 but were not included in the original baseline survey.The United States District Court for the District of Idaho granted summary judgment in favor of the environmental group, finding that the Project violated the Access Amendments and, therefore, the National Forest Management Act (NFMA) because total road mileage after the Project would exceed the 2011 baseline. The district court did not analyze whether the Project itself caused or contributed to the noncompliance with the baseline.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that, under NFMA and circuit precedent, a site-specific project is consistent with a forest plan so long as the project does not itself cause or worsen noncompliance with the plan’s requirements. The court found that the excess road mileage was entirely attributable to preexisting roads not caused by the Project, and that the Project would actually reduce total road mileage. The court also rejected arguments that the Project violated temporary road requirements. Thus, the Ninth Circuit reversed the district court’s judgment and remanded for further proceedings. View "ALLIANCE FOR THE WILD ROCKIES V. FOREST SERVICE" on Justia Law

Two individuals who were enrolled in a health insurance plan administered by a company alleged that their sensitive health information was disclosed without their authorization. In August 2023, the company sent each of them a letter explaining that an associate had mistakenly emailed a spreadsheet containing their private health information—including names, provider details, dates of service, and amounts billed or paid—to one or more other plan members. The plaintiffs asserted that they had entrusted this information to the company based on explicit and implicit promises of confidentiality and that the company’s privacy policy reinforced those expectations. They claimed the company’s unauthorized disclosure deprived them of the benefit of their bargain and diminished the value of the contracted services.Reviewing the case, the United States District Court for the District of Idaho dismissed the plaintiffs’ class action lawsuit on the grounds that they had not suffered an “injury in fact” necessary for Article III standing. The district court reasoned that disclosure of private information, without more, did not constitute a concrete injury and that the plaintiffs had not shown a substantial likelihood of future harm.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. The court held that the plaintiffs’ alleged harm—the unauthorized disclosure of sensitive health information entrusted on the basis of confidentiality—was analogous to the common law actions for breach of confidence and breach of contract, both of which were historically recognized as sufficient to support lawsuits. The court further noted that congressional judgment, as reflected in federal statutes like HIPAA, underscored the sensitivity of such information. Accordingly, the Ninth Circuit concluded that the plaintiffs had adequately alleged an injury sufficient for Article III standing, reversed the district court’s dismissal, and remanded the case for further proceedings. View "BLACK V. IEC GROUP, INC." on Justia Law

Three transgender children in Arizona, representing a class of all transgender individuals born in Arizona who wish to amend the sex marker on their birth certificates without undergoing a sex change operation, challenged the requirements for amending birth certificates. Arizona law, specifically A.R.S. § 36-337(A)(3), requires the registrar to amend a person’s birth certificate upon receiving a written request and a physician’s statement verifying a sex change operation. The plaintiffs argued that this “surgical requirement” violates the Equal Protection and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Arizona granted summary judgment for the plaintiffs, finding that the statute discriminated based on transgender status and burdened fundamental rights, thus applying heightened and strict scrutiny. The district court concluded the statute failed these standards and entered a permanent injunction, striking the word “operation” from the statute and its implementing regulation to allow amendments without proof of surgery.Upon review, the United States Court of Appeals for the Ninth Circuit clarified that Arizona’s statute provides two avenues for amending the sex marker on a birth certificate: through a physician’s verification of a sex change operation or by obtaining a court order. The court found that the law does not classify based on transgender status, but rather on whether an individual has undergone surgery, and that all individuals—including transgender people who have not had surgery—can seek a court order for amendment. Applying rational basis review, the court concluded the statute is rationally related to a legitimate state interest in ensuring adequate evidentiary support for amendments. The court also held that the statute does not violate due process, as it does not burden fundamental rights in all its applications. The Ninth Circuit reversed the district court’s summary judgment for the plaintiffs, vacated the permanent injunction, and remanded for further proceedings. View "ROE V. PETERSEN" on Justia Law

In August 2021, a city implemented a COVID-19 vaccination policy for its employees, requiring them to either receive the vaccine or request a medical or religious exemption. Employees granted an exemption were required to undergo weekly COVID-19 testing and wear masks in shared spaces. One employee, a forensic specialist, requested and received a religious exemption but objected to the testing and masking requirements, claiming they revealed his unvaccinated status and created a hostile work environment. He was placed on unpaid leave for refusing to comply but eventually agreed to the requirements and returned to work. He continued to challenge the policy until it was rescinded in March 2022.The employee filed suit in the United States District Court for the Central District of California, asserting federal and state claims against the city and several employees related to the testing and masking requirements. The district court found that the Public Readiness and Emergency Preparedness (PREP) Act applied but initially did not grant immunity to all individual defendants for each claim. Ultimately, the court dismissed the complaints, denied the employee’s motion for reconsideration, and entered judgment for the defendants.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that both the city and individual defendants were “covered persons” under the PREP Act, and that COVID-19 tests and masks constituted “covered countermeasures” authorized for emergency use. The court clarified that the causation requirement for PREP Act immunity is satisfied if the injury alleged arises from the administration or use of a covered countermeasure, regardless of the legal theory. Because the employee’s alleged harms were directly linked to the city’s COVID-19 safety policy, the court affirmed the district court’s dismissal and denial of reconsideration, holding that PREP Act immunity barred all claims. View "SCHMIDT V. CITY OF PASADENA" on Justia Law

Federal officials learned in December 2015 about a scheme to launder $5 million from South Korea to the United States for the purpose of bribing General Motors executives. The aim was for Woo Kyung M.I.T., a South Korean automotive supplier, to secure a lucrative GM contract. After a first payment, further funds were transferred through hawala brokers. Following an airport search, the bribe was delivered to Hyoung Nam “Brian” So. Shortly after, Woo Kyung M.I.T. was awarded the GM contract, but later withdrew due to profitability concerns and the ongoing investigation. Most of the bribe money was eventually returned, and South Korean officials arrested Lee, who pleaded guilty and cooperated with U.S. authorities.A formal request for evidence under the Mutual Legal Assistance Treaty (MLAT) was made to South Korea in July 2017, seeking documents and certifications relevant to the investigation. Several responses followed, with South Korean officials continuing efforts to provide requested certifications until October 2021. In September 2020, the government sought to toll the statute of limitations under 18 U.S.C. § 3292, citing ongoing requests for evidence. The U.S. District Court for the Central District of California issued a tolling order, suspending the statute of limitations for offenses described in the government’s application. On March 23, 2022, So was indicted for conspiracy to commit federal funds bribery. So moved to dismiss the indictment as untimely, but the district court found the offense covered by the tolling order and denied the motion. The court also refused to instruct the jury on the statute-of-limitations issue, ruling it was a question for the judge.On appeal, the United States Court of Appeals for the Ninth Circuit held that the tolling order applied to conspiracy to commit federal funds bribery, even though the offense was not specifically cited by statute. The panel concluded the indictment was timely, as final action by South Korean authorities occurred after the natural limitations period. The court also held that the district court properly resolved the statute-of-limitations issue without submitting it to the jury. The conviction and district court decisions were affirmed. View "USA V. SO" on Justia Law

A registered nurse working in a hospital’s Mother Baby Unit requested a religious exemption from her employer’s mandatory COVID-19 vaccination policy. Her request, which cited Christian beliefs regarding the sanctity of life and objections to the use of abortion-derived cell lines in vaccine development and testing, was denied. The hospital had followed an executive order issued by the Oregon governor, requiring all healthcare workers to be vaccinated unless granted a medical or religious exemption. The nurse was subsequently terminated for failure to comply with the vaccination mandate.The nurse filed suit in the United States District Court for the District of Oregon. She alleged a Free Exercise claim under 42 U.S.C. § 1983 against individual members of the hospital’s Board of Directors and Vaccine Exception Review Committee, and a Title VII claim against the hospital for failure to accommodate her religious beliefs. The district court granted the individual defendants’ motion to dismiss the Free Exercise claim on qualified immunity grounds, finding that the right to refuse a state-mandated vaccine on religious grounds was not clearly established in 2021. The court denied the hospital’s motion to dismiss the Title VII claim but later granted summary judgment for the hospital, holding that accommodating the nurse’s request would have imposed undue hardship due to health, safety, operational, and financial risks.The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s dismissal of the Free Exercise claim, holding that the individual defendants were entitled to qualified immunity because no clearly established law in 2021 recognized a healthcare worker’s religious right to a vaccine exemption under those circumstances. The court also affirmed summary judgment for the hospital on the Title VII claim, concluding that the hospital demonstrated undue hardship in accommodating the nurse without substantial risk to patients and operations. View "MACDONALD V. OREGON HEALTH AND SCIENCE UNIVERSITY" on Justia Law

The case involves William Castillo, who was convicted and sentenced to death for the murder of Isabelle Berndt in Las Vegas, Nevada. Castillo used a key he found while working as a roofer at Berndt’s home to later enter her residence with an accomplice, steal items, and fatally attack Berndt with a tire iron. Subsequently, he returned to the home to set it on fire. Evidence recovered from Castillo’s apartment linked him to the crime. He confessed to the robbery, murder, and arson during police interrogation and was convicted by a jury on multiple counts, including first-degree murder. The penalty phase included testimony regarding his abusive childhood and mental health, but the jury imposed a death sentence.After his conviction, Castillo appealed to the Nevada Supreme Court, which affirmed both the conviction and sentence. His state post-conviction relief (PCR) petition was denied by the trial court and affirmed by the Nevada Supreme Court. Castillo then filed a federal habeas corpus petition in the United States District Court for the District of Nevada. He voluntarily dismissed the petition, but later moved to reopen it. His subsequent amended petitions were dismissed by the district court as untimely or procedurally defaulted. The district court granted a certificate of appealability for four claims and denied it for two others.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that Castillo’s first and second amended habeas petitions were untimely and equitable tolling was not warranted. The court affirmed denial of relief on most claims, including ineffective assistance of trial counsel and the as-applied Eighth Amendment challenge to Nevada’s lethal injection protocol. However, the court reversed the district court’s ruling on two claims, finding that attorney error in state PCR proceedings could excuse procedural default under Martinez v. Ryan and Hogan v. Bean. Those claims were remanded for further proceedings. The court affirmed denial of certificates of appealability for the remaining claims. View "CASTILLO V. BEAN" on Justia Law

Several plaintiffs, who own downstream water rights on the Baker-Lehman Creeks in Nevada, alleged that activities by Great Basin National Park—including water diversion and vegetation planting—reduced water flow and threatened their ability to use water as determined by a 1934 Nevada state court decree. This decree (the Baker-Lehman Decree) set out the rights of all claimants to water from these creeks, which now originate and flow through federally managed land. The plaintiffs sought to enjoin the United States from activities that interfered with their water rights.The case began in Nevada state court, where plaintiffs filed to enforce their rights under the 1934 decree. The United States removed the case to the United States District Court for the District of Nevada and asserted sovereign immunity from suit. The district court found that sovereign immunity was not waived, reasoning that the McCarran Amendment did not apply because the United States did not participate in the original adjudication and thus the decree was not “comprehensive.” It dismissed the case for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the McCarran Amendment retroactively waives the United States’ sovereign immunity for suits seeking administration of water rights determined in a comprehensive state adjudication. The court found that the Baker-Lehman Adjudication was comprehensive under Nevada’s statutory system, regardless of the United States’ prior participation. The plaintiffs’ suit to enforce their adjudicated water rights constitutes administration under the McCarran Amendment. Accordingly, the Ninth Circuit reversed the district court’s dismissal and remanded the case, holding that the United States’ sovereign immunity was waived for this suit. View "BAKER RANCHES, INC. V. BURGUM" on Justia Law