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

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

Arizona voters approved Proposition 211, the Voters’ Right to Know Act, to address “dark money” in elections by requiring disclosure of the original sources of major campaign media spending, including contributions passed through intermediaries. The law applies to individuals and entities that spend significant amounts on campaign media, mandating public disclosure of donors who directly or indirectly contribute more than $5,000 per election cycle. It also includes recordkeeping requirements, opt-out provisions for donors, and enforcement by the Citizens Clean Elections Commission. Plaintiffs, Americans for Prosperity and its Foundation, alleged that these compelled disclosures and requirements violate their First Amendment rights by chilling speech and association, and they sought to enjoin the law.The case was first heard in the United States District Court for the District of Arizona. The plaintiffs advanced both facial and as-applied constitutional challenges. The district court applied the Supreme Court’s exacting scrutiny standard and dismissed all claims, finding Proposition 211 substantially related to Arizona’s strong informational interest, imposing only modest administrative burdens, and being narrowly tailored. The court noted the opt-out provision protected donors and that plaintiffs did not allege sufficient facts for an as-applied challenge.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Proposition 211’s disclosure requirements were substantially related to Arizona’s important governmental interest in electoral transparency, imposed modest burdens, and were narrowly tailored. The appellate court rejected the plaintiffs’ facial challenge, finding they did not demonstrate a substantial number of unconstitutional applications. The as-applied challenge failed for lack of specific allegations of harm. The court also affirmed the dismissal of compelled association claims, finding no unconstitutional compulsion. The disposition by the Ninth Circuit was to affirm the district court’s dismissal of all claims. View "AMERICANS FOR PROSPERITY V. MEYER" on Justia Law

An airline operating among the Hawaiian Islands faced severe financial difficulties over several years, leading to its abrupt shutdown in November 2017. The airline had previously been owned by a trust affiliated with a prominent individual, then partially sold to entities controlled by other businessmen. When the airline closed, employees received only one day's notice and did not receive their final paychecks. Following the closure, a Chapter 7 bankruptcy trustee was appointed. Together with two unions representing affected employees, the trustee initiated adversary proceedings against the airline’s former owners, directors, and lenders, alleging violations of Hawaii’s Dislocated Workers Act (DWA) and the federal WARN Act for failure to provide the required notice and compensation. Additional claims included breach of fiduciary duties and requests for equitable remedies such as veil piercing and equitable subordination.The proceedings began in the United States Bankruptcy Court for the District of Hawaii, but the District Court for the District of Hawaii withdrew the reference, consolidated the cases, and conducted a jury trial. The district court granted judgment as a matter of law for some claims and allowed others to proceed. The jury returned mixed verdicts, finding some defendants liable for statutory and fiduciary duty violations, but the court denied punitive damages and limited recovery to avoid double compensation. The court also ruled on equitable remedies, including piercing the corporate veil and equitably subordinating certain loans, and ordered contribution from a third-party defendant.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s judgment. It held that it had jurisdiction under 28 U.S.C. § 1291. The panel affirmed the trustee’s and unions’ Article III standing. It reversed in part on fiduciary duty claims, concluding that minority stakeholders and affiliated entities could owe fiduciary duties and be deemed “employers” under the DWA. The court clarified the statutory definition of “employer” and the scope of the DWA’s safe harbor defense, ruling it was unavailable absent a binding divestiture. The panel affirmed evidentiary rulings, vacated the nominal damages award due to erroneous jury instructions, affirmed the prohibition of punitive damages, and upheld the equitable remedies and contribution order. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "KANE V. PACAP AVIATION FINANCE, LLC" on Justia Law

Crown Resources Corporation and its parent company operated the Buckhorn Mountain Mine in Okanogan County, Washington, under a National Pollutant Discharge Elimination System (NPDES) permit issued by the Washington State Department of Ecology. Alleging violations of the Clean Water Act related to the mine’s discharges, both the Okanogan Highlands Alliance (OHA), a private environmental group, and the State of Washington filed separate citizen suits against Crown in 2020. The cases were consolidated and jointly litigated for several years. After mediation failed, OHA and Crown negotiated a settlement without Washington’s involvement. OHA and Crown submitted a proposed consent decree to the United States District Court for the Eastern District of Washington, which resolved OHA’s claims only. The district court entered the consent decree.Following the entry of the consent decree, Crown moved for judgment on the pleadings in Washington’s suit, arguing that the claims were barred by claim preclusion due to the prior resolution of OHA’s suit. The United States District Court for the Eastern District of Washington agreed, finding that Washington was in privity with OHA and thus barred from pursuing its claims. Washington’s motion for relief from judgment was denied, leading to this appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The Ninth Circuit held that Washington, not being a party to the consent decree and not in privity with OHA, was not barred from bringing its suit. The court found that the exceptions to nonparty preclusion identified in Taylor v. Sturgell did not apply here. Accordingly, the Ninth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "WASHINGTON V. CROWN RESOURCES CORP." on Justia Law

An incarcerated individual alleged that correctional officers at an Oregon prison denied him a decontamination shower after his exposure to pepper spray during an incident in a neighboring cell. He claimed the exposure caused pain and burning to his skin and lungs, and that his repeated requests for a shower were denied for two days. The inmate initiated the prison grievance process, submitting his first grievance form shortly after the incident and continuing through several rounds of administrative review and appeal, ultimately exhausting remedies as required under prison rules.The United States District Court for the District of Oregon dismissed the inmate’s lawsuit under 42 U.S.C. § 1983, finding it was barred by Oregon’s two-year statute of limitations for personal injury claims. The district court determined that the claims accrued on the date of exposure and tolled the limitations period only during a portion of the grievance process, starting when the prison received a second grievance. The court concluded the inmate filed his complaint out of time and declined to toll the period from the submission of the first grievance or the time between grievances.Reviewing the case, the United States Court of Appeals for the Ninth Circuit applied Oregon’s tolling statute, Oregon Revised Statutes § 12.210, which tolls the statute of limitations when a statutory prohibition prevents filing suit. The court held that federal law (42 U.S.C. § 1997e(a)) required exhaustion of administrative remedies before commencing a § 1983 action, and that the time spent in the grievance process does not count toward the statute of limitations. The tolling period began when the inmate initiated the grievance process and continued until exhaustion was complete. Consequently, the Ninth Circuit found the complaint timely filed, reversed the district court’s dismissal, and remanded for further proceedings. View "EDWARDS V. BROWN" on Justia Law

A white male employee of Seattle’s Human Services Department alleged that the City’s Race and Social Justice Initiative (RSJI) classified employees according to race, and that a series of workplace incidents—including racially aligned affinity groups, race-specific trainings, and racially offensive remarks from coworkers and supervisors—created a hostile work environment. He asserted that the RSJI and workplace conduct led to discrimination, retaliation, constructive discharge, and violation of his equal protection rights. After resigning in September 2021, he filed suit alleging claims under Title VII, the Washington Law Against Discrimination (WLAD), and the Equal Protection Clause.The United States District Court for the Western District of Washington dismissed as time-barred certain Title VII and WLAD claims based on acts predating statutory limitations periods. It granted summary judgment to the City on the remaining claims, finding insufficient evidence of actionable discrimination, retaliation, hostile work environment, constructive discharge, or equal protection violations. The court partially granted the City’s evidentiary objections to exhibits offered by the plaintiff.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s summary judgment de novo. The appellate court affirmed summary judgment for the City on the constructive discharge, disparate treatment, and retaliation claims, and also affirmed summary judgment on the Equal Protection Clause claim for lack of Article III standing. However, viewing the evidence in the light most favorable to the plaintiff, the Ninth Circuit reversed summary judgment on the hostile work environment claims under Title VII and WLAD, holding that there was a genuine issue of material fact as to whether the plaintiff was subjected to a racially hostile work environment. The case was remanded for further proceedings consistent with this determination. View "DIEMERT V. CITY OF SEATTLE" on Justia Law

Several employees of the Space and Missile Systems Center of the United States Air Force brought a qui tam action under the False Claims Act against Jeremy Burton, the Center’s former Deputy Chief Information Officer. The plaintiffs alleged that Burton, in coordination with a defense contractor, manipulated contract awards to ensure profits were shared in violation of federal regulations, thereby submitting fraudulent payment claims to the government.Initially, Burton moved to dismiss the claims, arguing that 31 U.S.C. § 3730(e)(1) barred the suit because he was a member of the armed forces, which would preclude jurisdiction over actions brought by one member of the armed forces against another arising out of military service. The United States District Court for the Central District of California first agreed and dismissed the claims against Burton. However, after further briefing on the status of the parties, the district court reconsidered and vacated its earlier order, concluding that Burton was a civilian employee and not a member of the armed forces. The suit was permitted to proceed, and Burton appealed before the case reached final judgment.The United States Court of Appeals for the Ninth Circuit examined whether it had jurisdiction to review the interlocutory order denying Burton’s defense under section 3730(e)(1). The court held that the district court’s order did not meet the requirements of the collateral order doctrine, specifically because it was not effectively unreviewable on appeal from a final judgment. The statute at issue was determined to be a jurisdictional bar, not an immunity from suit, and thus not subject to interlocutory appeal. The Ninth Circuit dismissed the appeal for lack of jurisdiction. View "UNITED STATES V. BURTON" on Justia Law

Two police officers attempted to execute a felony arrest warrant for a man believed to be affiliated with a local gang. The officers were aware of a recent incident in which the man had fled a traffic stop and believed he was an active fugitive wanted for serious drug-related offenses. Although the warrant had been recalled days before, the police database had not been updated, and the officers were unaware of this development. They located the man in a backyard, approached from ten to twenty feet away with their guns drawn, and ordered him to climb a fence and submit to arrest. The man claims both officers aimed their guns at his head, causing him fear and shock, but he complied without incident.After the arrest, the man was detained and later released when it was confirmed the warrant was no longer active. He filed a lawsuit in the United States District Court for the Central District of California, alleging the officers used excessive force in violation of his Fourth Amendment rights. The district court denied the officers’ motion for summary judgment, finding that a reasonable juror could conclude they used excessive force by aiming their weapons at the man’s head, and that this conduct was a clear violation of an established constitutional right.Reviewing the case, the United States Court of Appeals for the Ninth Circuit reversed the district court’s decision. The appellate court held that, under the circumstances, the officers did not violate the Fourth Amendment by approaching with weapons drawn, given their reasonable belief that the man was a serious and potentially dangerous fugitive who might resist or flee. The court further found that, even if excessive force had been used, there was no clearly established law making the officers’ conduct unlawful in these circumstances. The case was remanded with instructions to enter judgment for the officers. View "MEDRANO V. ACOSTA" on Justia Law

A Mexican citizen who entered the United States without inspection in 2000 faced removal proceedings initiated by the Department of Homeland Security in 2019. He admitted to the factual allegations and conceded removability. He applied for cancellation of removal and, alternatively, voluntary departure. The immigration judge denied cancellation of removal but granted voluntary departure, requiring him to post a $500 bond within five business days and depart within 60 days. The petitioner paid the bond the next day. When he appealed the denial of cancellation of removal to the Board of Immigration Appeals (BIA), he included proof of bond payment.The BIA dismissed the appeal and declined to reinstate the voluntary departure period, stating the record did not reflect timely proof of bond payment. This meant the alternate order of removal became effective. The BIA’s decision was issued more than 60 days after the immigration judge’s decision, so reinstatement of voluntary departure was necessary for the petitioner to depart voluntarily. The petitioner sought review from the United States Court of Appeals for the Ninth Circuit, arguing that the BIA failed to consider the proof of payment that was properly submitted.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to review legal errors under 8 U.S.C. § 1252(a)(2)(D), even though factual determinations underlying discretionary relief are generally unreviewable under Patel v. Garland, 596 U.S. 328 (2022). The court determined that the BIA’s failure to consider the dispositive evidence of bond payment constituted a legal error, not a factual determination. The court granted the petition for review in part and remanded for the BIA to consider the record evidence and decide whether to reinstate the voluntary departure period. The petition was denied as to cancellation of removal in a separate memorandum disposition. View "PEREZ-GARCIA V. BLANCHE" on Justia Law

A registered nurse employed by a hospital system in Oregon requested a religious exemption from her employer’s mandatory COVID-19 vaccination policy. She objected on two grounds: concerns about vaccine safety for pregnant women and a religious objection to the use of fetal cells derived from abortions in vaccine development, citing her Christian beliefs and relevant biblical passages. After submitting her exemption request, the employer placed her on indefinite unpaid leave, leaving her without health insurance or income during her third trimester of pregnancy.The United States District Court for the District of Oregon reviewed her complaint, which referenced but did not attach the exemption letter. The hospital moved to dismiss, arguing the complaint failed to plausibly allege a conflict between the vaccination policy and the nurse’s bona fide religious beliefs. A magistrate judge recommended denying the motion, finding the allegations sufficient at the pleading stage, but the district court disagreed. It dismissed the complaint as too conclusory, without leave to amend and without considering the exemption letter attached to the plaintiff’s opposition to the motion to dismiss. Judgment was entered, and the plaintiff appealed.The United States Court of Appeals for the Ninth Circuit held that the district court erred in dismissing the complaint. The appellate court ruled that the exemption letter was central to the plaintiff’s claim and should have been considered under the incorporation-by-reference doctrine. Upon review of the letter, the Ninth Circuit found that the plaintiff had plausibly alleged a prima facie Title VII religious discrimination claim. The court reversed the district court’s dismissal and remanded for further proceedings. View "RIDINGS V. PEACEHEALTH" on Justia Law