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

The claimant stopped working in December 2018 due to gastrointestinal complications attributed to anxiety and subsequently sought Social Security disability insurance benefits. She alleged disability based on a combination of mental and physical impairments, including PTSD, panic disorder, ADHD, major depressive disorder, fibromyalgia, and irritable bowel disease. Her initial application was denied by the Social Security Administration both initially and upon reconsideration. She requested a hearing before an administrative law judge (ALJ), who found her not disabled after reviewing her impairments and concluded that she retained the capacity to perform light work with certain limitations.After the Appeals Council denied her request for further review, the claimant filed a civil action in the United States District Court for the Western District of Washington. The district court affirmed the ALJ’s denial of benefits, maintaining that the ALJ’s findings were supported by substantial evidence.Upon appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The court held that the ALJ erred in finding unpersuasive the opinion of the claimant’s treating physician regarding her fibromyalgia, and also erred in rejecting the claimant’s testimony about her physical impairments and symptoms without providing convincing reasons. Additionally, the ALJ failed to provide any reason for disregarding lay testimony from the claimant’s partner, which constituted legal error under the “germane reasons” standard. However, the ALJ’s evaluation of medical opinions from other doctors and rejection of the claimant’s testimony about her mental impairments were supported by substantial evidence.The Ninth Circuit reversed the district court’s judgment and remanded with instructions for further administrative proceedings, concluding that an immediate award of benefits was inappropriate. View "FAIN V. BISIGNANO" on Justia Law

The case concerns an individual who entered the United States without inspection and was placed in removal proceedings after being detained by immigration authorities. While in custody, he was properly served with a Notice to Appear and provided the detention center address as his location. Shortly before his release, his relatives posted a bond and filled out a bond form with his residential address and telephone number, but not his mailing address. The relatives were unaware that the individual received mail via a P.O. Box and not at his residential address. After release, the government sent a hearing notice to the residential address listed on the bond form, but the notice was returned as undeliverable since mail could not be received at that address.An Immigration Judge ordered the individual removed in absentia after he failed to appear at the hearing, relying on the assumption that he had received written notice. The individual, who did not know about the hearing, promptly moved to reopen the proceedings, providing his correct mailing address and explaining, via sworn statements, that he had notified the court of his address for receiving notices and had lived at the same location since release. The Immigration Judge denied the motion to reopen, applying a presumption of delivery based on regular mail. The Board of Immigration Appeals affirmed, concluding that the government had complied with statutory notice requirements by sending notice to the last known address and rejecting the argument that he was entitled to actual notice.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the government violated the petitioner’s due process rights by relying solely on a residential address provided by third parties on a bond form, which was not reasonably calculated to provide notice. The court granted the petition for review, vacated the removal order, and remanded for further proceedings. The court dismissed a later petition for review as moot. View "MEDINA V. BLANCHE" on Justia Law

After the Snake River Basin Adjudication (SRBA) confirmed thousands of federal stockwater rights on federal land, Idaho enacted a series of statutes known as the “stockwater amendments.” These amendments altered water rights rules, including procedures for forfeiture and appurtenance, and imposed new requirements specifically affecting federal stockwater rights. The United States challenged several provisions, arguing that they were intended to divest it of SRBA-decreed stockwater rights and unlawfully discriminated against the federal government. Two groups—the Idaho Legislature and ranching interests—intervened as defendants.The United States District Court for the District of Idaho rejected jurisdictional challenges based on Rooker-Feldman, prior exclusive jurisdiction, Burford abstention, and claim preclusion, holding it could hear the case. On the merits, the district court found Idaho Code § 42-224 constitutional as applied to the United States, but held Idaho Code §§ 42-113(2)(b), 42-502, and 42-504 were facially unconstitutional under the Supremacy Clause. The United States appealed the ruling on § 42-224, while the State Defendants and Ranchers cross-appealed the jurisdictional holdings and the ruling on § 42-113(2)(b).The United States Court of Appeals for the Ninth Circuit affirmed the district court’s jurisdictional holdings, concluding that neither the doctrine of prior exclusive jurisdiction nor Burford abstention applied. The panel reversed the district court’s finding that § 42-224 was constitutional as applied, holding that it is part of a statutory scheme that unlawfully discriminates against the United States and jeopardizes its SRBA-decreed rights. The panel affirmed the district court’s holding that § 42-113(2)(b) is facially unconstitutional because it singles out the United States for unfavorable treatment by changing appurtenance rules only for rights associated with federal land. Thus, the Ninth Circuit affirmed in part and reversed in part, awarding costs to the United States. View "USA V. STATE OF IDAHO" on Justia Law

Two inmates who identify as transgender women brought a class action against the Oregon Department of Corrections and related officials, alleging Eighth Amendment violations for purportedly exposing transgender women inmates to substantial risk of harm by housing them in men’s prisons. The plaintiffs sought a preliminary mandatory injunction on behalf of a class of all current and future transgender women in Oregon prison facilities, requesting that they be presumptively assigned to the state’s women’s prison and given additional protections.A magistrate judge in the United States District Court for the District of Oregon granted the motion for a preliminary injunction and provisionally certified the class. The injunction required Oregon to presumptively assign transgender women inmates to the women’s prison unless a specific security justification was documented, along with other measures for safety and privacy. Defendants moved for reconsideration, and the district court amended but largely maintained the injunction. Defendants appealed and obtained a stay of the injunction pending appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s order, applying an abuse-of-discretion standard to the injunction and de novo review to underlying legal issues. The Ninth Circuit found the district court committed clear error by basing its injunction on an unsupported finding that the defendants employed a default presumption of housing transgender women in men’s prisons. The appellate court determined that the record showed individualized assessments for inmate placement and that the plaintiffs failed to demonstrate a likelihood of success on the merits, irreparable harm, or commonality for class certification. The Ninth Circuit vacated the preliminary injunction, ordered the class to be decertified, and remanded the case. The mandate was issued forthwith. View "S.D. V. REESE" on Justia Law

Two American entrepreneurs established three international corporations to invest in the casino and gaming industry in Laos. Two of these corporations became involved in disputes with the Government of the Lao People’s Democratic Republic (Lao PDR), resulting in multiple arbitration proceedings in Singapore. The tribunals issued monetary awards in favor of Lao PDR against the two companies. Lao PDR tried to collect the awards through various means, including contacting corporate officers, filing suits abroad, and pursuing enforcement actions in U.S. courts. After an unsuccessful attempt in Idaho, Lao PDR filed a petition in the United States District Court for the Northern Mariana Islands to enforce the arbitral awards, asserting that the entrepreneurs and their third corporation, Bridge Capital, were alter egos of the award-debtor corporations and should also be liable.The District Court for the Northern Mariana Islands granted a joint motion by Baldwin and Bridge Capital to dismiss the petition, concluding that it lacked jurisdiction under the Federal Arbitration Act (FAA) to enforce the awards against parties not named as debtors in the arbitral awards. The court reasoned that Lao PDR would need to bring a separate action to pursue enforcement against alleged alter egos. The court stayed a similar motion by Scott pending the present appeal.Upon review, the United States Court of Appeals for the Ninth Circuit held that the district court had subject matter jurisdiction under 9 U.S.C. § 203 because the awards arose from a commercial, international relationship and were foreign arbitral awards under the New York Convention. The appellate court determined that the district court was required to consider the merits of Lao PDR’s alter ego theory in a single enforcement proceeding, rather than requiring a separate action. The Ninth Circuit reversed the district court’s dismissal and remanded for further proceedings. View "THE GOVERNMENT OF THE LAO PEOPLE'S DEMOCRATIC REPUBLIC V. BALDWIN" on Justia Law

Programmers who published open-source code on GitHub sued GitHub, Microsoft, and various OpenAI entities, alleging that GitHub Copilot and Codex—AI tools trained on publicly available code from GitHub—reproduce portions of their code without attribution. These programmers claimed that the AI’s omission of copyright management information (CMI), such as attribution and license terms required by open-source licenses, violated the Digital Millennium Copyright Act (DMCA), specifically 17 U.S.C. § 1202(b). Plaintiffs alleged that Copilot’s outputs sometimes consist of verbatim or near-verbatim reproductions of their code, but the AI-generated outputs do not include the original CMI.The United States District Court for the Northern District of California reviewed the case and dismissed the DMCA claims under Rule 12(b)(6, first with leave to amend and then with prejudice, concluding that plaintiffs failed to allege that Copilot’s outputs were “identical” to their code and that only identical copies from which CMI had been removed could support a DMCA claim. The court allowed breach of contract claims to proceed. It certified the DMCA dismissal for interlocutory appeal under 28 U.S.C. § 1292(b), noting the issue of whether § 1202(b) imposes an identicality requirement.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The court held that plaintiffs had Article III standing due to a plausible risk of injury. However, it determined that under their “output” theory, Copilot and Codex do not “remove or alter” CMI from copies of existing protected works; instead, they generate new works that never contained CMI. The court declined to consider the plaintiffs’ “input” theory as it was forfeited. The main holding is that generating new works without CMI does not violate § 1202(b) of the DMCA. View "DOE V. GITHUB, INC." on Justia Law

Louis Mendonsa pleaded guilty in April 2024 to seven counts of distribution and one count of possession of child pornography, stemming from activities on several “dark web” websites between July and November 2022. Decades earlier, Mendonsa was convicted in California state court for multiple child sex abuse offenses, including lewd and lascivious acts and oral copulation with minors he supervised as newspaper delivery boys. Most of these prior convictions involved the same victim and resulted in a 14-year prison sentence.The United States District Court for the Eastern District of California, in calculating Mendonsa’s federal sentence, applied a five-level enhancement under U.S.S.G. § 2G2.2(b)(5) for engaging in a pattern of activity involving the sexual abuse or exploitation of a minor. The original presentence report did not recommend this enhancement, but following the government’s objection and submission of evidence from Mendonsa’s 1993 convictions, the final report included it. Mendonsa objected, arguing both that the enhancement should not apply to conduct from thirty years prior and that the evidence was insufficient to establish two separate qualifying incidents. At sentencing, the district court found multiple distinct instances of sexual abuse based on state-court documents and applied the enhancement. Mendonsa was sentenced to 292 months in prison and appealed.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that § 2G2.2(b)(5) is ambiguous regarding whether it covers conduct outside the offense of conviction, and that the Sentencing Guidelines commentary reasonably interprets the enhancement to include such conduct. The court further concluded that the categorical approach does not apply since the enhancement focuses on conduct, not convictions, and found no clear error or abuse of discretion in the district court’s reliance on hearsay evidence or its factual findings. The sentence was affirmed. View "USA V. MENDONSA" on Justia Law

Two federally recognized tribes sued several entities, including Kalshi and Robinhood, alleging that Kalshi’s “event contracts”—which pay based on sports outcomes—amounted to unauthorized sports betting offered on tribal lands. The tribes argued this violated the Indian Gaming Regulatory Act (IGRA) and their own gaming ordinances, since only tribally authorized gaming is lawful under secretarial procedures that stand in place of a tribal-state compact. They also challenged Kalshi’s advertisement claiming sports betting was legal nationwide on its platform under the Lanham Act.The United States District Court for the Northern District of California denied the tribes’ motion for a preliminary injunction. The court concluded that the transactions did not occur on Indian lands, found Kalshi not bound by any tribal compact or procedures, and determined that the Unlawful Internet Gambling Enforcement Act (UIGEA) controlled Kalshi’s conduct. The court reasoned that UIGEA exempted Kalshi’s contracts because they were regulated by the Commodity Exchange Act (CEA). The Lanham Act claim was rejected as the challenged advertisement was deemed a nonactionable opinion about legality.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the denial of the preliminary injunction in part. The court held that the tribes were likely to succeed on their IGRA claims, finding Kalshi’s sports contracts constituted class III gaming, occurred on Indian lands when entered into from tribal territory, and were unauthorized under the tribes’ ordinances and secretarial procedures. The court determined that neither UIGEA nor CEA displaced IGRA’s remedies or barred the tribes’ claim. However, the Ninth Circuit affirmed the district court’s rejection of the Lanham Act claim, holding Kalshi’s advertisement was a lay opinion. The case was remanded for consideration of the remaining preliminary injunction factors. View "BLUE LAKE RANCHERIA V. KALSHI, INC." on Justia Law

Late at night, Anchorage police officers responded to reports of a domestic disturbance involving Kristopher Handy and his girlfriend. Dispatchers informed the officers that Handy had assaulted his girlfriend, may have discharged a firearm, and was seen waiting for the police outside his apartment, armed with a shotgun. Upon arrival, officers announced themselves and ordered Handy to come out and drop his weapon. Handy exited with the shotgun, refused repeated instructions to disarm, and advanced toward the officers while waving his shotgun overhead and cursing. As Handy stepped off the curb, officers fired, fatally shooting him.Plaintiffs, relatives of Handy, filed suit in the United States District Court for the District of Alaska, alleging excessive force in violation of the Fourth Amendment and deprivation of familial association. Defendants moved to dismiss on grounds of qualified immunity. The district court denied the motion, reasoning that, viewed in the light most favorable to plaintiffs, Handy’s actions did not necessarily constitute an immediate threat warranting deadly force. The court cited Ninth Circuit precedents suggesting an officer may not use deadly force against an armed suspect unless the suspect makes a threatening gesture, and found that factual disputes about Handy’s behavior precluded dismissal.Upon appeal, the United States Court of Appeals for the Ninth Circuit determined it had jurisdiction over the interlocutory appeal and reviewed the facts de novo. The court held that, considering the totality of the circumstances and the incorporated video evidence, the officers acted reasonably and did not violate Handy’s or plaintiffs’ federal rights. The court also found no clearly established law requiring officers to hold fire until a suspect aimed a weapon at them. Accordingly, the Ninth Circuit vacated the district court’s denial of qualified immunity and remanded with instructions to grant qualified immunity to the officers. View "HANDY V. JONES" on Justia Law

The defendant was convicted in 2006 for robbing a liquor and convenience store in Hawaii, during which he assaulted the store owner and stole cash from the premises. He was found guilty by a jury on four counts: conspiracy to commit Hobbs Act robbery, Hobbs Act robbery, brandishing a firearm during a violent crime, and being a felon in possession of a firearm. At sentencing, the United States District Court for the District of Hawaii applied several enhancements under the Sentencing Guidelines, including a career-offender enhancement based on prior state burglary convictions, resulting in a total sentence of 24 years.Following sentencing, the United States Sentencing Commission enacted four amendments to the Guidelines, three of which were not retroactive. If all had applied retroactively, the defendant’s sentence would have been significantly shorter. In 2024, the defendant moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), arguing that the disparity between his sentence and what he would receive under current Guidelines constituted an extraordinary and compelling reason for sentence reduction. The district court denied the motion, citing the policy statement in U.S.S.G. § 1B1.13, which precludes consideration of nonretroactive Guidelines changes as extraordinary and compelling reasons.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial for abuse of discretion and the interpretation of statutes and Guidelines de novo. The court held that the Sentencing Commission acted within its statutory authority in promulgating the policy statement, which validly bars courts from considering nonretroactive Guideline amendments—whether individually or in combination—as extraordinary and compelling reasons for compassionate release. The Ninth Circuit affirmed the district court’s denial of the defendant’s motion. View "USA V. TROIANO" on Justia Law