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

Six former employees of a regional public transportation agency challenged the agency’s mandatory COVID-19 vaccination policy, asserting that it failed to accommodate their sincere religious objections to vaccination. In late 2021, the agency required all employees to be fully vaccinated unless exempted for medical or religious reasons. The agency’s leave management department evaluated religious exemption requests and determined that 70 employees qualified for potential accommodations but ultimately concluded that none could be accommodated without undue hardship. These employees were told to get vaccinated or lose their jobs; many resigned, retired, or were terminated.A group of former employees who lost their jobs filed suit in the United States District Court for the Northern District of California, bringing claims under Title VII, the California Fair Employment and Housing Act (FEHA), and 42 U.S.C. § 1983 (alleging a violation of their right to free exercise of religion). The district court granted summary judgment for the defendant on the § 1983 claim and denied summary judgment on the other claims. After consolidation and a first trial that ended in a mistrial on the defendant’s undue hardship defense, six employees proceeded to a second trial. There, a jury found in their favor, awarding over $7.8 million in damages. The district court denied the defendant’s renewed motion for judgment as a matter of law and its request for a new trial.On appeal, the United States Court of Appeals for the Ninth Circuit held that the employer was not entitled to judgment as a matter of law or a new trial. The court concluded that the employees established a prima facie case and that the employer failed to prove that accommodating the employees’ religious objections would have caused an undue hardship, as required by law. The appellate court affirmed the district court’s judgment. The court also found no reversible error in the remedial order and deemed the cross-appeal on the free exercise claim moot. View "LEWIS-WILLIAMS V. SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT" on Justia Law

A former police officer for a federally recognized Indian tribe was terminated from his position and subsequently brought a lawsuit in federal court against several of his superior officers and the tribe's general counsel. His claims, brought against these individuals in their personal capacities, included federal civil rights causes of action under 42 U.S.C. §§ 1981, 1985(2), and 1985(3), a Bivens claim, and a state tort claim for intentional interference with contractual relations. He did not sue the tribe itself. The complaint alleged that the defendants treated him less favorably than Native American employees, subjected him to a racially hostile work environment, interfered with his court testimony, and conspired to deprive him of due process in his employment and reputation.The United States District Court for the District of Nevada dismissed the action. The court held that the individual defendants were entitled to absolute personal immunity, and, alternatively, that the tribe was a required party under Federal Rule of Civil Procedure 19 that could not be joined due to tribal sovereign immunity. The court did not address arguments regarding tribal sovereign immunity or qualified immunity as independent grounds for dismissal.The United States Court of Appeals for the Ninth Circuit reversed. The court held that tribal sovereign immunity does not bar suits seeking money damages from tribal officials in their individual capacities where any judgment would not operate against the tribe itself. The court further held that the individual defendants were not entitled to absolute immunity, as the functions at issue—personnel and employment decisions—were not historically protected by such immunity at common law. Additionally, the tribe was not a required party under Rule 19 because it lacked a legally protected interest that could be impaired by the litigation’s outcome. The court remanded for the district court to address any qualified immunity defenses in the first instance. View "ERWINE V. WESTBROOK" on Justia Law

Two college football players began their collegiate athletic careers at junior colleges in 2019 before transferring to NCAA Division I institutions. Both completed the maximum five years of collegiate eligibility allowed by the NCAA’s “Five-Year Rule,” which includes time spent at any full-time collegiate institution, including junior colleges. In 2025, each player sought a preliminary injunction in the United States District Court for the District of Nevada, arguing that the NCAA’s five-year limitation on eligibility was anticompetitive under Section 1 of the Sherman Act and seeking to play an additional, sixth year of college football. The players also challenged the NCAA’s “Rule of Restitution,” which allows the NCAA to penalize member schools that permit ineligible athletes to compete pursuant to court orders later vacated or reversed.Both district courts granted the plaintiffs’ requests for preliminary injunctions, permitting them to play in the 2025 college football season. After the season concluded, the NCAA appealed the injunctions to the United States Court of Appeals for the Ninth Circuit. The plaintiffs moved to dismiss the appeals as moot because the 2025 season was over and their collegiate eligibility had ended.The United States Court of Appeals for the Ninth Circuit held that the appeals were moot, as the injunctions had expired and the players’ collegiate careers were over, making it impossible to provide any effective relief to the NCAA. The court further determined that the NCAA did not meet its burden to show that the case fit the “capable of repetition yet evading review” exception to mootness, because there was no reasonable expectation that these plaintiffs would again be subject to the same NCAA actions. Accordingly, the Ninth Circuit dismissed the NCAA’s appeals as moot and vacated the district courts’ orders. View "BRAHAM V. NATIONAL COLLEGIATE ATHLETIC ASSOCIATION" on Justia Law

A college baseball player challenged the National Collegiate Athletic Association’s rule that limits athletes to four seasons of eligibility within five years of their initial college enrollment. After exhausting his five years of eligibility through a series of transfers between NCAA and non-NCAA institutions, including one school that closed during his attendance, the athlete sought a waiver to compete in an additional season at a Division I university. The request for a waiver was denied by both the conference and the NCAA.The athlete filed suit in the United States District Court for the District of Nevada, alleging that the Five-Year Rule violated Section 1 of the Sherman Act and sought a preliminary injunction to allow him to play during the pending litigation. The district court granted the injunction, concluding that the NCAA’s rule was a commercial restraint subject to antitrust scrutiny and that the athlete was likely to succeed on the merits of his claim.On appeal, the United States Court of Appeals for the Ninth Circuit held that, consistent with recent decisions from other circuits and in light of NCAA v. Alston, the Five-Year Rule is indeed a commercial restraint subject to review under the Sherman Act. However, the Ninth Circuit determined that the district court abused its discretion by finding a likelihood of success on the merits. The appellate court found the evidentiary support for the athlete’s antitrust claim to be insufficient, particularly regarding the definition of the relevant market and the demonstration of substantial anticompetitive effects. As a result, the Ninth Circuit vacated the preliminary injunction, holding that the athlete failed to meet his burden to show a likelihood of success on the merits of his antitrust claim. View "BLYTHE V. NATIONAL COLLEGIATE ATHLETIC ASSOCIATION" on Justia Law

A helicopter owned and operated by the Huntington Beach Police Department crashed in 2022, resulting in the death of Officer Nicholas Vella and serious injury to Officer RJ Garwood. The plaintiffs alleged that the crash was caused by a defect in the helicopter’s stability augmentation system. The helicopter, a model MD520N, was manufactured by The Boeing Company in 1998 and delivered to the police department that same year. It had a seating capacity of five and was type and airworthiness certified by the Federal Aviation Administration (FAA).The plaintiffs initially brought their claims for strict products liability, breach of warranties, and negligence in California state court. The case was removed to the United States District Court for the Central District of California on the basis of diversity jurisdiction. The defendants, including The Boeing Company and MacD Helicopters, moved to dismiss, arguing that the claims were barred by the General Aviation Revitalization Act’s (GARA) 18-year statute of repose. The plaintiffs contended that GARA did not apply to “public aircraft” such as those owned by governmental entities. The district court rejected the plaintiffs’ arguments, found that the helicopter met GARA’s definition of “general aviation aircraft,” and granted the motions to dismiss. The court certified its decision for interlocutory appeal and stayed further proceedings.The United States Court of Appeals for the Ninth Circuit considered whether GARA’s statute of repose applied to the police helicopter. The court held that the statute’s definition of “general aviation aircraft” includes government-owned aircraft, as long as the statutory requirements are met. The panel expressly rejected the argument that the Federal Aviation Act’s “public aircraft” definition is incorporated into GARA and concluded that GARA contains no “public aircraft” exception. The Ninth Circuit affirmed the district court’s dismissal of the lawsuit. View "VELLA V. MACD HELICOPTERS, INC." on Justia Law

A coalition composed of individuals, corporations, trade associations, labor unions, nonprofits, and public utilities brought suit in the Western District of Washington seeking declaratory and injunctive relief. Their claims challenged the Washington State Energy Code, arguing that it is preempted by federal law and restricts the installation and maintenance of natural gas appliances, impacting their energy preferences and causing economic harm. The plaintiffs named as defendants the individual members of the Washington State Building Code Council, who had adopted the Energy Code, as well as the Washington Attorney General, all in their official capacities.The United States District Court for the Western District of Washington reviewed the case first. All defendants moved to dismiss the complaint, citing sovereign immunity and standing. The district court granted the motion to dismiss solely on the basis of sovereign immunity, dismissing the plaintiffs’ complaint without prejudice and denying leave to amend. Plaintiffs then appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The Ninth Circuit affirmed the district court’s dismissal, holding that Eleventh Amendment sovereign immunity barred the plaintiffs’ suit. The court determined that the named defendants did not have a sufficient connection with the enforcement of the Energy Code to be subject to suit under the Ex parte Young exception. The Councilmembers’ promulgation of the Energy Code and their issuance of non-binding advisory opinions did not constitute enforcement, and the Attorney General’s role did not exceed a generalized duty to enforce state law. Thus, all defendants were shielded by sovereign immunity, and the district court’s judgment was affirmed. View "RIVERA V. ANDERSON" on Justia Law

An individual incarcerated at a California state prison suffers from a spinal condition causing severe pain and limited mobility, and also experiences incontinence. For nearly a year, prison staff provided him with adult diapers as a medical accommodation. However, after a transfer to a different housing unit, his access to these supplies was abruptly terminated, and his requests for reinstatement were denied for almost five months. During this period, he was forced to soil himself and his environment, resulting in humiliation and distress, despite repeated written and verbal requests for accommodation.He filed a lawsuit in the United States District Court for the Northern District of California, alleging violations of the Americans with Disabilities Act (ADA) and the Eighth Amendment. The district court granted summary judgment in favor of the California Department of Corrections and Rehabilitation (CDCR) and other defendants, concluding he was not entitled to relief under the ADA because it found no evidence of discrimination due to his disability and determined his claims for injunctive relief were moot once supplies were reinstated.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment as to the ADA claim. The appellate court held that a reasonable jury could find the plaintiff is disabled under the ADA due to his spinal condition and incontinence, that he was denied meaningful access to toileting and hygiene services because of his disabilities, and that this denial was because of his disabilities. The court further found there was sufficient evidence to create a triable issue as to whether CDCR acted with deliberate indifference, a necessary element for damages. The panel also clarified that a public entity is not excused from ADA obligations merely because an accommodation is not deemed medically necessary. The case was remanded for further proceedings, including consideration of standing for injunctive relief. View "ADOM V. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION" on Justia Law

During a contentious custody dispute, Allen Gessen faced state kidnapping charges after attempting to remove his son from the country in violation of a court order. Seeking sole custody, Gessen initially tried to bribe an immigration official to deport the mother of his two children, Priscilla Chigariro. Ultimately, he opted for a murder-for-hire scheme as a cheaper, more permanent solution. Gessen met twice with a broker—who was actually an undercover FBI agent—and agreed to pay $50,000 for the murder, providing a gold coin and wiring approximately $23,000 to a San Francisco account. He also supplied detailed information about Chigariro’s whereabouts. On the planned day of the murder, Gessen was arrested, and a grand jury charged him with murder-for-hire under 18 U.S.C. § 1958.The United States District Court for the Northern District of California presided over Gessen’s trial. The government presented evidence including audio recordings and testimony from the undercover agent and Chigariro. Gessen testified that he only wanted Chigariro deported, not killed, but the jury found him guilty. Gessen requested jury instructions reflecting his theory that a murder-for-hire conviction requires a real agreement with a hitman, and challenged venue in California, arguing that the crime was complete before any acts occurred in that district. The district court rejected these instructions, ruling they were unsupported by law, and denied motions for acquittal and a new trial, finding sufficient evidence and proper venue. Gessen was sentenced to 120 months in prison.The United States Court of Appeals for the Ninth Circuit affirmed the conviction. The court held that 18 U.S.C. § 1958 does not require an actual agreement with a hitman or proof of a quid pro quo; intent on the part of the defendant alone suffices. Venue was proper in any district touched by the continuing offense, including the Northern District of California. The district court’s jury instructions and evidentiary rulings were upheld. View "USA V. GESSEN" on Justia Law

The case involves an individual, Perez, who entered the United States after completing compulsory military service in El Salvador, where he served as a radio operator in the Fourth Infantry Brigade and was occasionally loaned to the Atonal Battalion, an elite unit associated with severe human rights abuses. Perez and his wife sought immigration relief under the Nicaraguan Adjustment and Central American Relief Act (NACARA), claiming fear of persecution by guerrillas. During his application and subsequent proceedings, Perez’s testimony contained contradictions regarding his role and actions during his military service, including statements about firing his weapon, witnessing abuses, and his association with the Atonal Battalion. The Immigration Judge (IJ) found Perez not credible due to these inconsistencies and denied his NACARA application, citing his failure to rebut the persecutor bar, lack of credibility, and perjury.Perez appealed to the Board of Immigration Appeals (BIA), which affirmed the IJ’s adverse credibility finding. The BIA determined that Perez’s ties to the Atonal Battalion were sufficient to raise the persecutor bar under NACARA, shifting the burden to Perez to prove the bar did not apply. The BIA concluded Perez failed to rebut the bar due to his lack of credibility and held that even if Perez were credible, a duress defense was foreclosed by the Attorney General’s interpretation in Matter of Negusie.The United States Court of Appeals for the Ninth Circuit reviewed the petition. The court determined that the persecutor bar does not contain an implied duress defense and that the statutory text excludes such an exception. The court accorded limited weight to the agency’s interpretation, finding the best reading of the statute is to deny a duress defense. The court denied Perez’s petition for review. View "PEREZ-CASTILLO V. BLANCHE" on Justia Law

A noncitizen from Guatemala was ordered removed in absentia after arriving five minutes late to his immigration merits hearing, claiming a flat tire caused his tardiness. He filed a timely, pro se motion to reopen and rescind the removal order, explaining the circumstances in detail and including a receipt for new tires purchased weeks later as gratitude to the tire shop that made the emergency repair. He asserted that the flat tire constituted an “exceptional circumstance” beyond his control.The Immigration Judge acknowledged that the petitioner’s explanation was not inherently unbelievable and that a flat tire could qualify as an exceptional circumstance. However, the judge denied the motion because the petitioner did not supply adequate documentary evidence directly corroborating his claim, such as a same-day repair receipt, and noted there were no administrative records of the phone calls the petitioner claimed were made to the court. The Board of Immigration Appeals dismissed his appeal, concluding that he failed to provide sufficient evidence or an affidavit under penalty of perjury to meet his burden.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the Board of Immigration Appeals erred by imposing evidentiary requirements inconsistent with Ninth Circuit precedent. Specifically, the court held that pro se petitioners are not required to submit a separate formal affidavit under penalty of perjury and that the agency must generally accept a petitioner’s credible explanation as true unless it is inherently unbelievable, without demanding corroborative documentary evidence. The Ninth Circuit granted the petition for review and remanded the case for reconsideration under the correct evidentiary standard. View "TRIGUEROS QUIZAR V. BLANCHE" on Justia Law