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

The case involves Orlonzo Hedrington, who underwent heart surgery and subsequent rehabilitation at a Veterans Administration medical center in California. Hedrington alleged that, during his discharge, he was sexually assaulted by nursing staff and administered drugs to disguise the assault. He filed a timely administrative claim with the Department of Veterans Affairs, which was denied. Hedrington then filed a timely lawsuit under the Federal Tort Claims Act (FTCA), claiming negligence.The United States District Court for the Eastern District of California first reviewed Hedrington’s timely FTCA action (“Hedrington I”). The United States moved for summary judgment, raising issues related to judicial estoppel and standing due to Hedrington’s bankruptcy proceedings. After the bankruptcy trustee was substituted as plaintiff, the district court denied the United States’s summary judgment motion. Later, Hedrington filed a second, untimely pro se lawsuit (“Hedrington II”), which was removed to the same district court. The court dismissed Hedrington II as time-barred under the FTCA. Subsequently, the United States moved for summary judgment in Hedrington I, asserting claim preclusion based on the judgment in Hedrington II. The district court granted summary judgment on both claim preclusion and insufficient evidence.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Hedrington I was not barred by claim preclusion. Following Filice v. United States, the Ninth Circuit applied California claim preclusion law, under which a dismissal for untimeliness does not have claim preclusive effect. Additionally, the court found that applying claim preclusion here would result in manifest injustice, triggering California’s public policy exception. The Ninth Circuit reversed the district court’s summary judgment on claim preclusion and remanded for further proceedings. View "HEDRINGTON V. USA" on Justia Law

Jeffrey Olson leased a Jeep Grand Cherokee from a car dealership under a lease agreement that included an arbitration provision and a delegation clause, which assigned questions about the scope of arbitration to an arbitrator. FCA US, LLC, the manufacturer of the Jeep, was not a signatory to the lease agreement. Olson later became the named plaintiff in a federal class-action lawsuit against FCA, alleging defects in the vehicle’s headrest system. FCA, not being a party to the lease, sought to compel Olson to arbitrate the dispute based on the arbitration agreement between Olson and the dealership.The United States District Court for the Eastern District of California denied FCA’s motion to compel arbitration. The district court found that FCA, as a non-signatory to the lease agreement, could not enforce the arbitration provision or its delegation clause against Olson. The court concluded that the arbitration agreement applied only to Olson and the dealership (including its employees, agents, successors, or assigns), and FCA did not qualify under any of those categories. Additionally, the court rejected FCA’s argument that it could use equitable estoppel to compel arbitration, holding that none of Olson’s claims were sufficiently intertwined with the lease agreement to justify such an exception under California law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that FCA could not compel Olson to arbitrate because FCA was not a party to the arbitration agreement and no applicable exception—such as equitable estoppel—applied. The court clarified that, under both federal and California law, only parties to an arbitration agreement (or those qualifying under specific, limited exceptions) may enforce it. The court also rejected FCA’s reliance on Supreme Court precedent, finding it inapplicable to non-signatories in these circumstances. View "OLSON V. FCA US, LLC" on Justia Law

Federal agents identified the defendant as the source of fentanyl that caused a fatal overdose in Goleta, California. Their investigation revealed that he had been selling drugs for years, frequently operating from his apartment. A search of the apartment uncovered nearly $13,000 in cash, various tools associated with drug distribution, and significant quantities of cocaine, fentanyl, methamphetamine, and Alprazolam. The defendant admitted that the cash was proceeds from drug dealing and that a safe in his bedroom was primarily used to store drugs and drug proceeds. His phone also contained substantial evidence indicating his apartment functioned as the center of his drug-trafficking activities.A grand jury indicted the defendant for possession with intent to distribute multiple controlled substances. He pleaded guilty to all charges without a plea agreement. At sentencing, the United States District Court for the Central District of California considered—over defense objection—a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a premises for the purpose of manufacturing or distributing a controlled substance. The defendant argued that his apartment was primarily his residence, not a stash house, and that the enhancement should not apply. The district court found ample evidence that the apartment was used as a place to sell drugs and imposed the enhancement, ultimately sentencing the defendant to 105 months’ imprisonment.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s application of the sentencing enhancement for abuse of discretion and affirmed the sentence. The court held that the enhancement under § 2D1.1(b)(12) applies when a defendant regularly uses his home for substantial drug trafficking, even if the residence also serves as his primary home. The Ninth Circuit found no abuse of discretion in the district court’s determination that drug trafficking was a primary or principal use of the apartment. The sentence was affirmed. View "USA V. TEKOLA" on Justia Law

A consumer purchased a licorice product manufactured by a Minnesota company, relying on packaging that stated the product was “Naturally Flavored,” “Natural Strawberry & Raspberry Flavored Licorice,” and “Free of . . . Artificial Colors & Flavors.” The consumer later learned, through laboratory testing, that the product contained DL malic acid, which is an artificial flavor created from petrochemical sources. The consumer alleged that this ingredient rendered the product’s labeling false or misleading, and filed a putative class action in California, asserting claims for violation of the California Consumers Legal Remedies Act, unjust enrichment, and breach of express warranty.The United States District Court for the Southern District of California dismissed the complaint with prejudice. The court found that the complaint failed to plead with sufficient particularity that the malic acid was artificial, thus not meeting the heightened pleading standard of Federal Rule of Civil Procedure 9(b). The district court also held that the plaintiff did not plausibly allege that a reasonable consumer would be misled by the product’s labeling, reasoning that the labels did not explicitly state the product was “all natural” or “100% natural,” and that the ingredients list disclosed both natural and artificial ingredients.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The appellate court held that the complaint satisfied Rule 9(b) because it identified the specifics of the alleged fraud and provided details about the laboratory testing. The court also held that the plaintiff plausibly alleged that a reasonable consumer could be misled by the product’s claim to be free of artificial flavors when it allegedly contained an artificial flavor. The case was remanded for further proceedings. View "TRAMMELL V. KLN ENTERPRISES, INC." on Justia Law

A man was convicted in California state court of first-degree murder, rape, and sodomy arising from the 1988 killing of a woman at an apartment lodge where both lived. On the day of the crime, the man consumed large amounts of alcohol and interacted repeatedly with the victim, ultimately assaulting and killing her in her apartment. Physical evidence and the man’s own detailed post-arrest confessions were central to the prosecution’s case; he admitted to deliberating about ensuring the victim’s death after an initial assault. The defense at trial argued intoxication, but the jury convicted him of first-degree murder and found a special circumstance, leading to a death sentence.After the California Supreme Court affirmed the convictions and special circumstances (but reversed a robbery charge), the man pursued state and federal habeas relief. His federal habeas petition alleged, among other things, that the prosecution withheld exculpatory blood-alcohol test results (a Brady claim) and that trial counsel was ineffective for failing to investigate and present additional evidence of intoxication and mental impairment (Strickland claims). The U.S. District Court for the Central District of California initially denied most relief but later set aside the murder conviction and special circumstance finding based on the Brady and Strickland claims.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court. The Ninth Circuit held that under AEDPA’s deferential standards, the California Supreme Court could reasonably have concluded that there was insufficient factual support for the existence of undisclosed blood-alcohol test results and that counsel’s alleged failures did not prejudice the defense. The Ninth Circuit directed the district court to deny habeas relief as to the convictions and special circumstances, remanding solely for resolution of any remaining penalty-phase claims. View "BRADFORD V. VANG" on Justia Law

Decabromodiphenyl Ether (decaBDE) is a flame retardant used in numerous products, including electronics, vehicles, and appliances, and is known for its persistence, bioaccumulation, and toxic effects on human and environmental health. In response to concerns about such chemicals, Congress amended the Toxic Substances Control Act (TSCA) in 2016, adding a subsection mandating expedited risk-management rules for certain chemicals, including decaBDE. The Environmental Protection Agency (EPA) promulgated rules in 2021 and amended them in 2024, regulating some uses of decaBDE but declining to regulate exposures arising from recycling, disposal, wastewater, and sewage sludge in several contexts.Following the 2021 rule, several petitioners challenged the EPA’s approach in the United States Court of Appeals for the Ninth Circuit. The EPA voluntarily sought a remand to reconsider aspects of its rule, which the Ninth Circuit granted. After seeking additional public comment, the EPA issued the 2024 amendments, which still did not address all the petitioners’ concerns, particularly regarding the areas of recycling, disposal, wastewater discharges, and sewage sludge. The petitioners renewed their challenge, arguing that EPA’s failure to regulate these areas violated TSCA’s mandate.The United States Court of Appeals for the Ninth Circuit concluded that the EPA’s decisions not to further regulate decaBDE exposures in recyclable articles, disposal, wastewater, and sewage sludge were not supported by substantial evidence as required by TSCA. The court held that EPA could not justify a failure to regulate based on low exposure levels or general policy preferences and found the agency had not adequately addressed evidence in the record. The court granted the petition for review, remanded the rule to the EPA for renewed rulemaking and further proceedings, but left the 2024 rule in place during the remand. View "YUROK TRIBE V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY" on Justia Law

The defendant, a person of Mexican descent, worked at a tax preparation business serving Spanish-speaking clients in Boise, Idaho. He was indicted on seven counts of preparing and presenting false and fraudulent tax returns. During jury deliberations, it became undisputed that one juror made racially biased comments about Mexicans. This juror, identified as Juror 5, participated in nearly all deliberations and expressed views suggesting animus toward Mexicans, including remarks about how Mexicans "hate Americans" and allegations connecting the defendant's employer to criminal activity.After the biased statements were reported, the United States District Court for the District of Idaho conducted a special voir dire with all jurors to determine the impact of the comments. Several jurors confirmed hearing the remarks, but most denied being influenced by them. The district court excused Juror 5 for good cause but allowed the remaining eleven jurors to continue deliberations without instructing them to start anew. Thirteen minutes later, the jury returned a partial verdict. The defendant moved for a mistrial and later for a new trial, arguing that his Sixth Amendment right to an impartial jury was violated. The district court denied both motions, applying the standard from United States v. Sarkisian, which asks whether exposure to prejudicial comments tainted the verdict.On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court applied an incorrect legal standard. The Ninth Circuit concluded that the proper standard is from United States v. Remmer, which presumes prejudice when juror bias is discovered before a verdict is accepted, and places a heavy burden on the government to prove harmlessness. The court found that the government failed to rebut this presumption, and therefore reversed the district court’s denial of the motion for a new trial and remanded for a new trial. View "USA V. SANCHEZ" on Justia Law

John Chapman, who has multiple neurodevelopmental disorders, maintained a romantic relationship with Jamie Feden for several years, despite being married to another woman. In 2019, Chapman and Feden traveled together from Pennsylvania to Las Vegas. Prior to and during this period, Chapman conducted online searches related to murder and body disposal. While in Nevada, Chapman took Feden to a remote desert location, restrained her with zip ties and duct tape under the pretense of a bondage photoshoot, and ultimately caused her death by asphyxiation. He left her body in the desert and returned to Pennsylvania, where he used her phone to communicate with her friends and family to conceal her death. After suspicions arose, Chapman was questioned by police and confessed to the crime after being read his Miranda rights.The United States District Court for the District of Nevada denied Chapman’s motion to suppress his confession, finding that he had knowingly and intelligently waived his Miranda rights and that his confession was voluntary. During trial, Chapman argued his mental conditions affected his perception and intent. After lengthy deliberations and substantive jury notes indicating a deadlock, the district court gave an Allen charge and made coercive comments to a holdout juror. The jury returned a guilty verdict for kidnapping resulting in death. Chapman’s post-verdict motions for acquittal and a new trial were denied.The United States Court of Appeals for the Ninth Circuit vacated Chapman’s conviction and remanded for a new trial, finding impermissible jury coercion due to the undisclosed jury notes, the coercive Allen charge, and the court’s direct comments to a holdout juror. The court also held, for the first time in the circuit, that the “holding” element of the federal kidnapping statute can be satisfied by non-physical means such as deception. The court affirmed the denial of the motion to suppress Chapman’s confession. View "USA V. CHAPMAN" on Justia Law

A native and citizen of Honduras entered the United States without admission or parole and was taken into custody. Shortly after her release, the Department of Homeland Security (DHS) served her with a Notice to Appear, written in English, which informed her of the obligation to notify the immigration court of any change of address. She provided an address in Hanford, California, which was used for subsequent correspondence. After moving to a new address without notifying the immigration court, she missed a scheduled removal hearing, and was ordered removed in absentia.The Immigration Judge (IJ) denied her motion to reopen the removal proceedings, finding that she had received proper notice by mail to her last known address. Her subsequent motion to reconsider was also denied; the IJ found she had constructive notice because the Notice to Appear was sent to her last provided address, and that she had been properly informed of her obligation to update her address. On appeal, the Board of Immigration Appeals (BIA) upheld the IJ’s decisions, concluding that jurisdiction was not impacted by the allegedly defective Notice to Appear, and that mailing the Notice of Hearing to her last provided address was sufficient under the applicable statutory and Supreme Court precedent.On review, the United States Court of Appeals for the Ninth Circuit held that DHS is not constitutionally required to provide a translation of the entirety of a Notice to Appear—including the obligation to update an address—in an alien’s native language. The court found that English-language notices are generally sufficient to satisfy due process because they are reasonably calculated to inform recipients of their obligations. The petition for review was denied. View "URQUIA-YANEZ V. BLANCHE" on Justia Law

A creditor and her law firm, holding pre-bankruptcy judgments against a debtor, sought to recover assets from the debtor's Chapter 7 bankruptcy estate. The debtor had declared bankruptcy in 2011, disclosing interests in two Los Angeles properties. The Chapter 7 trustee initially reported no assets available for distribution. After protracted litigation regarding exemptions and the value of the properties, including appeals, the creditor asserted the trustee had failed to preserve estate assets by allowing the properties to deteriorate and by not collecting rental income that could benefit the estate.The creditor began an adversary proceeding against the trustee, alleging gross negligence and breach of fiduciary duty related to the management of estate property. The United States Bankruptcy Court for the Central District of California dismissed the complaint with prejudice, finding the trustee was protected by quasi-judicial immunity because the conduct amounted, at most, to ordinary negligence and was time-barred. On appeal, the United States District Court for the Central District of California affirmed dismissal on the grounds of immunity, but reversed the statute of limitations ruling and remanded for consideration of whether amendment of the complaint would be futile.Upon further appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, held it had jurisdiction to review the district court’s order, given the creditor’s counsel’s representation that they would not amend the complaint. The Ninth Circuit clarified that a bankruptcy trustee may have quasi-judicial immunity only for actions involving discretionary judgment essential to adjudicating private rights in the estate. The court held that the trustee’s alleged failures in property management and rent collection were administrative, not adjudicative, and thus not protected by quasi-judicial immunity. The court also found the trustee was not entitled to derived judicial immunity on the current record. The decision of the district court was reversed and remanded for further proceedings. View "PHILLIPS V. GOLDMAN" on Justia Law