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

Several unions representing approximately 800,000 federal civilian employees challenged an executive order issued by the President in March 2025. This order, Executive Order 14,251, invoked statutory authority to exclude various federal agencies and subdivisions from collective bargaining rights, citing national security concerns. The agencies affected included the Departments of State, Justice, Veterans Affairs, and others, and the order was accompanied by White House and Office of Personnel Management statements which asserted that union activities impeded national security functions. The unions alleged that the President’s action constituted unlawful retaliation against them for engaging in protected First Amendment activities, including lawsuits and public criticism of the Administration.The case originated in the United States District Court for the Northern District of California. There, the judge granted a preliminary injunction, enjoining the enforcement of Executive Order 14,251 on the grounds that the unions raised a serious question as to whether the order was issued in retaliation for their protected speech. The district court focused on statements in the White House’s supporting materials, finding these reflected hostility toward the unions’ activities. The court did not address the merits of the unions’ other claims.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. The Ninth Circuit agreed that the district court had jurisdiction to hear the unions’ claims, rejecting the government’s argument that the unions were required to pursue administrative remedies before the Federal Labor Relations Authority. However, the Ninth Circuit vacated the preliminary injunction. The appellate court held that, even if the unions made a prima facie showing of retaliation, the government demonstrated that the President would have issued the order regardless of the unions’ protected conduct, due to legitimate national security concerns. Because the unions did not show a likelihood of success or serious questions on the merits, the preliminary injunction was vacated. View "AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO V. TRUMP" on Justia Law

A man was convicted of first-degree murder, kidnapping, and sexual abuse in connection with the 1989 killing of a woman. The prosecution relied heavily on testimony from a codefendant, who received a plea deal and testified that the defendant killed the victim after a dispute over drugs. Other witnesses, including the victim’s family and friends, corroborated aspects of the prosecution’s account. The defendant’s counsel presented a misidentification defense and a mere-presence defense, but the jury found him guilty and he was sentenced to death after the trial court determined the crime was especially cruel, heinous, or depraved.Following the initial conviction, the Arizona Supreme Court reversed some convictions and remanded for a retrial, after which the defendant was again convicted and sentenced to death. On direct appeal, the Arizona Supreme Court affirmed the conviction and sentence, finding both aggravating factors met and that mitigating evidence, including the defendant’s abusive childhood and substance abuse, did not outweigh aggravation. The defendant filed state postconviction petitions, arguing ineffective assistance of counsel at both the guilt and penalty phases, and raising issues about mitigation evidence. Both the trial court and Arizona Supreme Court denied relief, often finding the claims procedurally barred or unsupported.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of federal habeas relief. The court held that most guilt-phase ineffective assistance claims were procedurally defaulted and not excused under Martinez v. Ryan, as the defendant failed to show cause and prejudice. The court found one claim—failure to retain a forensic expert to challenge testimony about the victim’s gurgling—was not defaulted, but concluded the state court reasonably found no prejudice given overwhelming evidence of guilt. The court also found the Arizona Supreme Court reasonably rejected penalty-phase ineffective assistance claims and denied a certificate of appealability on the claim regarding mitigation evidence and the causal nexus test. The judgment of the district court was affirmed. View "DETRICH v. THORNELL" on Justia Law

A dispute arose over the operation of the Klamath Project, a large federal water management system serving both agricultural and wildlife needs in Northern California and Southern Oregon. The Bureau of Reclamation manages the project, which involves distributing water from Upper Klamath Lake, a reservoir that also provides habitat for endangered and threatened species, including two species of suckers and coho salmon. In response to ongoing drought and the listing of these species under the Endangered Species Act (ESA), the Bureau consulted with federal wildlife agencies and adopted procedures requiring minimum water levels and stream flows to protect the listed species. Competing interests include tribal fishing rights, agricultural irrigation, and wildlife conservation.The conflict intensified when the Klamath Water Users Association and Klamath Irrigation District challenged the Bureau’s authority to release water from Upper Klamath Lake to comply with the ESA, arguing such releases diminished water available for irrigation and exceeded the Bureau’s authority under state and federal law. The Oregon Water Resources Department issued an order to halt these releases, which led federal agencies and tribal groups to seek declaratory and injunctive relief in the United States District Court for the Northern District of California. The district court held that the Bureau's operations were subject to the ESA and enjoined enforcement of the state order.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed whether the ESA applies to the Bureau’s operation of the Klamath Project, whether the district court’s order constituted a judicial taking of water rights, and whether the district court had jurisdiction. The Ninth Circuit held that Section 7(a)(2) of the ESA applies to the Bureau’s Klamath Project operations, reaffirming its precedent that the ESA governs such federal water management actions. The court rejected the judicial taking claim, finding no adjudication of water rights occurred, and determined that neither prior exclusive jurisdiction nor Colorado River abstention doctrines barred the district court from deciding the case. The Ninth Circuit affirmed the district court’s decision. View "YUROK TRIBE V. KLAMATH WATER USERS ASSOCIATION" on Justia Law

The petitioner was convicted in Arizona of first-degree murder, kidnapping, attempted transfer of a dangerous drug, and attempted arson. The crimes involved a failed drug transaction in which the petitioner, after threatening a victim, ultimately abducted and killed him with an accomplice. Following the crime, the petitioner, his girlfriend, and his accomplice attempted to destroy evidence by burning a vehicle, but were apprehended after a police chase. Substantial physical evidence and testimony, including from the girlfriend who accepted a plea bargain, linked the petitioner to the offenses. At sentencing, the petitioner, after consulting with counsel, declined to present mitigating evidence and was sentenced to death.The Arizona Supreme Court affirmed the convictions and death sentence, although it reversed one aggravating factor and independently reweighed the remaining factors. The petitioner’s first state post-conviction relief (PCR) petition was denied on the merits, and later PCR petitions asserting additional ineffective assistance of counsel (IAC) claims were dismissed as precluded. In federal habeas proceedings in the United States District Court for the District of Arizona, the petitioner raised several IAC claims, some of which relied on evidence not presented in state court. The district court denied relief, finding some claims procedurally defaulted and others meritless, and declined to expand the record or hold an evidentiary hearing.The United States Court of Appeals for the Ninth Circuit affirmed. It held that, under 28 U.S.C. § 2254(e)(2) and Shinn v. Ramirez, the district court properly declined to consider evidence not presented in state court. The panel rejected the petitioner’s IAC claims, finding no unreasonable application of federal law or evidence of prejudice, and held that procedural defaults were not excused. It also denied certification for additional claims, finding no substantial showing of a constitutional violation. View "RIENHARDT V. THORNELL" on Justia Law

A former seasonal employee of a package delivery company filed suit against her employer, alleging violations of California labor laws, including wage-related claims and a Private Attorneys General Act (PAGA) claim. She had signed an arbitration agreement as a condition of employment, which included a class action waiver and a delegation clause assigning threshold arbitrability issues to an arbitrator. The agreement specified that the Federal Arbitration Act (FAA) would govern unless it did not apply, in which case state law would control. After her work schedule was repeatedly changed or canceled with little notice, she was not given further work despite her inquiries and subsequently initiated legal action on behalf of herself and proposed classes.After the case was removed from state court, the United States District Court for the Central District of California granted the employer’s motion to compel arbitration of the individual claims and stayed class claims. The district court declined to decide whether the FAA or the California Arbitration Act (CAA) governed the agreement, reasoning that the result would be the same under either statute. The court also denied the employee’s motion for clarification, maintaining that the question of which law applied and whether the FAA’s “contracts of employment” exclusion was relevant could be resolved by the arbitrator rather than the court.On mandamus review, the United States Court of Appeals for the Ninth Circuit held that the district court committed clear legal error by failing to determine whether the FAA or state law governed the arbitration agreement before compelling arbitration. The Ninth Circuit emphasized that, under New Prime Inc. v. Oliveira, the court—not an arbitrator—must decide whether the FAA applies, including any statutory exclusions. The Ninth Circuit granted the writ of mandamus, directing the district court to vacate its prior order and to determine the statutory basis for its authority to compel arbitration before referring the parties to arbitration. View "ORR V. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, RIVERSIDE" on Justia Law

Forward, Inc. operates a landfill near Stockton, California, which is bordered by several state facilities. Forward was required by a local water quality board to remediate groundwater contamination at its landfill. During this process, Forward suspected that nearby state facilities—including correctional and health care centers—were contributing hazardous waste to the groundwater, hindering its remediation efforts. Forward entered into an agreement with two California state agencies to access these facilities and collected data suggesting ongoing hazardous waste generation stemming from activities such as dry cleaning, solvent use, and well-water treatment at the state facilities.Forward filed suit in the United States District Court for the Eastern District of California under the Resource Conservation and Recovery Act (RCRA), seeking injunctive and declaratory relief against the Secretary of the California Department of Corrections and Rehabilitation (CDCR) and the Director of the California Department of General Services (DGS). Forward alleged that, due to their official positions, these defendants had control over the generation, handling, storage, and disposal of hazardous waste at the relevant facilities. The district court granted the defendants’ motion to dismiss for lack of subject matter jurisdiction, concluding that Forward had not established a sufficiently direct connection between the defendants and the alleged violations under the Ex parte Young exception to Eleventh Amendment sovereign immunity.The United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. It affirmed the district court’s ruling, holding that Forward failed to establish the “fairly direct” connection required by Ex parte Young. The court found that the defendants’ general supervisory roles over their respective agencies did not suffice to subject them to suit for the alleged RCRA violations, as neither their statutory duties nor alleged actions were directly tied to the waste management at the specific state facilities. The Ninth Circuit’s disposition was to affirm the district court’s dismissal. View "FORWARD, INC. V. MACOMBER" on Justia Law

Joaquin Ciria was convicted in 1991 for the murder of Felix Bastarrica in San Francisco, based largely on the testimony of George Varela, who was 18 at the time and an accomplice to the actual shooter. The conviction rested primarily on Varela’s statement, which he later recanted, claiming that police investigators threatened him with prosecution and fed him a story implicating Ciria. There was no physical evidence linking Ciria to the crime, and eyewitnesses could not positively identify him. In 2022, after serving thirty-two years, Ciria was exonerated when new evidence and witness statements showed he was factually innocent, and it was revealed that the investigators had used coercive tactics during their interrogation of Varela.Following his exoneration, Ciria filed a federal civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of California. He alleged that San Francisco Police Inspectors James Crowley and Arthur Gerrans fabricated evidence and maliciously prosecuted him. The district court denied Crowley and Gerrans’s motion for qualified immunity on Ciria’s fabrication-of-evidence and malicious prosecution claims, concluding that a reasonable jury could find the officers had used coercive interrogation tactics and lacked probable cause to charge Ciria.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of qualified immunity. The court held that, viewing the facts in the light most favorable to Ciria, a reasonable jury could find that the officers threatened and coerced a key witness into fabricating evidence against Ciria and that, as of 1990, it was clearly established that such conduct would violate due process rights. The Ninth Circuit also held that the officers were not entitled to qualified immunity on the malicious prosecution claim because, without the coerced statement, it was not reasonably arguable that probable cause existed to charge Ciria. The court’s decision was affirmed. View "CIRIA V. GERRANS" on Justia Law

In 1985, Gerald Ross Pizzuto, Jr. was convicted by a jury in Idaho state court of murdering Berta and Del Herndon during a robbery, and he was sentenced to death. Over the following decades, Pizzuto challenged his conviction and death sentence through numerous state and federal post-conviction proceedings, but those efforts were unsuccessful. In 2021, Pizzuto sought clemency from the Idaho Commission of Pardons and Parole, which recommended that his death sentences be commuted to life without parole. However, the Governor of Idaho rejected this recommendation in accordance with an Idaho statute requiring gubernatorial approval for commutation in capital cases.Following the Governor’s denial, Pizzuto argued in Idaho state court that the Governor lacked authority under the Idaho Constitution to overrule the Commission’s recommendation. The Idaho Supreme Court upheld the statute granting the Governor final authority in capital commutation cases, concluding that a 1986 amendment to the Idaho Constitution permitted the legislature to establish the procedures for granting clemency. Pizzuto filed a petition for rehearing, asserting that the Idaho Supreme Court’s decision was so arbitrary as to violate his federal due process rights, but the Idaho Supreme Court summarily denied rehearing.Pizzuto then brought a habeas corpus petition in the United States District Court for the District of Idaho, raising the due process claim. The district court denied relief, finding that the claim was not cognizable in federal habeas and would fail on the merits. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that Pizzuto’s claim essentially challenged the Idaho Supreme Court’s interpretation of state law, which is not a cognizable federal habeas claim. Even if the claim were cognizable, the court determined that Pizzuto did not demonstrate a due process violation under clearly established federal law, and the Idaho Supreme Court’s decision was not so arbitrary as to support habeas relief. View "PIZZUTO V. VALLEY" on Justia Law

The defendant entered the United States in 1999 and remained without legal status after his tourist visa expired in 2000. He applied for and received a Washington concealed pistol license in 2019, falsely claiming to be a U.S. citizen. He also submitted Bureau of Alcohol, Tobacco, Firearms, and Explosives forms indicating citizenship to register handguns. A series of domestic violence incidents led to multiple restraining orders against him, each including a prohibition on owning or possessing firearms. Law enforcement seized firearms, ammunition, and a silencer from his residence in 2022. The defendant admitted to being a Brazilian citizen and acknowledged that he was not permitted to possess firearms due to his immigration status and domestic violence convictions.The United States District Court for the Western District of Washington denied the defendant’s motions to dismiss charges on Second Amendment, materiality, and vagueness grounds. The defendant was convicted in a bench trial based on stipulated facts for unlawful possession of firearms and ammunition as a noncitizen and as a person under a domestic violence restraining order, making false statements during firearm purchases, falsely claiming U.S. citizenship, and unlawful possession of a firearm silencer.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed all convictions. The court held that precedent from United States v. Vazquez-Ramirez controlled challenges to 18 U.S.C. § 922(g)(5)(A), confirming the constitutionality of prohibiting firearm possession by noncitizens unlawfully present. Materiality challenges to false statement convictions failed because the Second Amendment does not protect firearm possession by such individuals. The court found that United States v. Rahimi and United States v. VanDyke foreclosed challenges to convictions based on domestic violence restraining orders. The court held that the National Firearms Act’s silencer regulations do not violate the Second Amendment or the Fifth Amendment’s vagueness doctrine. The panel affirmed the district court’s judgment. View "USA V. DEBORBA" on Justia Law

California officials challenged a determination by the Federal Motor Carrier Safety Administration (FMCSA) that California’s meal and rest break (MRB) rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted by federal law. The MRB rules require employers to provide drivers with specified meal and rest periods during the workday. The FMCSA concluded that these state rules regulated commercial motor vehicle safety, were more stringent than federal hours-of-service (HOS) regulations, and imposed requirements not found in federal law.Previously, in 2019, the American Bus Association petitioned the FMCSA to preempt California’s MRB rules for passenger-carrying drivers. After public notice and comment, the FMCSA issued a final order in 2020 preempting these rules, finding they added no measurable safety benefit beyond federal HOS rules, were incompatible with federal regulations, and placed an unreasonable burden on interstate commerce. California officials petitioned the United States Court of Appeals for the Ninth Circuit for review of the FMCSA’s preemption decision.The United States Court of Appeals for the Ninth Circuit reviewed the FMCSA’s action under the highly deferential standard of the Administrative Procedure Act. It held that its earlier decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021), foreclosed California’s main arguments and confirmed that the FMCSA had authority to preempt the MRB rules. The court also held that the FMCSA’s determination that the MRB rules imposed an unreasonable burden on interstate commerce was supported by the administrative record and not arbitrary or capricious. The petition for review was denied, and the FMCSA’s preemption determination was upheld. View "PEOPLE OF THE STATE OF CAL. V. FMCSA" on Justia Law