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

Gina Champion-Cain operated a Ponzi scheme through her company ANI Development, LLC, defrauding over 400 investors of approximately $389 million. The SEC initiated a civil enforcement action, freezing Cain’s and ANI’s assets, appointing a receiver for ANI, and temporarily staying litigation against ANI. Defrauded investors then sued third parties, including Chicago Title Company and the Nossaman law firm, alleging their involvement in the scheme.The United States District Court for the Southern District of California approved a global settlement between the Receiver and Chicago Title, which included a bar order preventing further litigation against Chicago Title and Nossaman related to the Ponzi scheme. Kim Peterson and Ovation Fund Management II, LLC, whose state-court claims against Chicago Title and Nossaman were extinguished by the bar orders, challenged these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the district court had the authority to enter the bar orders because the claims by Peterson and Ovation substantially overlapped with the Receiver’s claims, seeking recovery for the same losses stemming from the Ponzi scheme. The bar orders were deemed necessary to protect the ANI receivership estate, as allowing the claims to proceed would interfere with the Receiver’s efforts and deplete the receivership’s assets.The Ninth Circuit also concluded that the Anti-Injunction Act did not preclude the bar orders, as they were necessary in aid of the district court’s jurisdiction over the receivership estate. The court rejected Peterson’s argument that the bar order was inequitable, noting that Peterson had the opportunity to file claims through the receivership estate but was determined to be a net winner from the Ponzi scheme. Consequently, the Ninth Circuit affirmed the district court’s bar orders. View "USSEC V. CHICAGO TITLE COMPANY" on Justia Law

An underage user of the Grindr application, John Doe, filed a lawsuit against Grindr Inc. and Grindr LLC, alleging that the app facilitated his sexual exploitation by adult men. Doe claimed that Grindr's design and operation allowed him to be matched with adults despite being a minor, leading to his rape by four men, three of whom were later convicted. Doe's lawsuit included state law claims for defective design, defective manufacturing, negligence, failure to warn, and negligent misrepresentation, as well as a federal claim under the Trafficking Victims Protection Reauthorization Act (TVPRA).The United States District Court for the Central District of California dismissed Doe's claims, ruling that Section 230 of the Communications Decency Act (CDA) provided Grindr with immunity from liability for the state law claims. The court also found that Doe failed to state a plausible claim under the TVPRA, as he did not sufficiently allege that Grindr knowingly participated in or benefitted from sex trafficking.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that Section 230 barred Doe's state law claims because they implicated Grindr's role as a publisher of third-party content. The court also agreed that Doe failed to state a plausible TVPRA claim, as he did not allege that Grindr had actual knowledge of or actively participated in sex trafficking. Consequently, Doe could not invoke the statutory exception to Section 230 immunity under the Allow States and Victims to Fight Online Sex Trafficking Act of 2018. The Ninth Circuit affirmed the district court's dismissal of Doe's claims in their entirety. View "DOE V. GRINDR INC." on Justia Law

Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law

Frankie Greer filed a lawsuit against the County of San Diego under 42 U.S.C. § 1983, claiming he suffered serious injuries while incarcerated in the San Diego Central Jail. During discovery, Greer requested documents from the County’s Critical Incident Review Board (CIRB) meetings related to in-custody deaths. The CIRB’s purpose is to consult with legal counsel on incidents that may lead to litigation, assess civil exposure, and recommend remedial actions. The district court ruled that the CIRB documents were not protected by attorney-client privilege, as the CIRB served multiple purposes beyond obtaining legal advice. After Greer settled his claims, several media organizations intervened to unseal the CIRB documents.The United States District Court for the Southern District of California denied the County’s motion for reconsideration and ordered the production of the CIRB documents, which were then produced under an attorneys’-eyes-only protective order. The district court also granted the media organizations' motion to intervene and unseal the documents, leading to the County’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the appeal was not moot, as effective relief could still be provided by ordering the return or destruction of the CIRB documents. The court determined that the attorney-client privilege applied to the CIRB documents, as the primary purpose of the CIRB meetings was to obtain legal advice regarding potential litigation and to avoid future liability. The court found that the district court had made significant legal errors in its determination and that the County had not waived the privilege. The Ninth Circuit reversed the district court’s order and remanded with instructions to require the return and/or destruction of the privileged documents. View "GREER V. COUNTY OF SAN DIEGO" on Justia Law

Three inmates in a California state prison jointly filed a lawsuit under 42 U.S.C. § 1983, alleging Eighth Amendment violations and false imprisonment due to being forced to stand in unsanitary conditions for nearly nine hours. One inmate also claimed excessive force. They applied to proceed in forma pauperis (IFP).The United States District Court for the Eastern District of California denied their request for joinder and severed their claims, requiring each inmate to file separately. The court reasoned that the Prison Litigation Reform Act (PLRA) required each prisoner to pay the full filing fee, and allowing joint actions would result in fees exceeding statutory limits. The court also cited practical issues with pro se prisoner lawsuits, such as potential transfers and communication difficulties, as reasons for denying joinder.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the PLRA does not prohibit prisoners from proceeding together in lawsuits, but it does require each prisoner to pay the full filing fee. The district court erred by interpreting the PLRA's fee provisions in isolation and failing to harmonize them. The Ninth Circuit also found that the district court abused its discretion in denying permissive joinder under Rule 20 of the Federal Rules of Civil Procedure based on hypothetical concerns not supported by the record.The Ninth Circuit reversed the district court's decision, allowing the inmates to proceed jointly under the PLRA, provided each pays the full filing fee. View "JOHNSON V. HDSP" on Justia Law

In this case, G.P.P., Inc. (GIS) sued Guardian Protection Products, Inc. (Guardian) and RPM Wood Finishes Group, Inc. (RPM) for breach of contract and other claims related to nine warehousing distributor agreements (WDAs). GIS alleged that Guardian wrongfully terminated three WDAs and threatened to terminate the remaining six. GIS sought damages and other relief, while Guardian countersued for declaratory relief and breach of contract.The United States District Court for the Eastern District of California conducted two trials. In the first trial, the jury rejected all claims and counterclaims. GIS appealed, and the Ninth Circuit reversed the district court's summary judgment on certain claims, leading to a second trial. In the second trial, the jury awarded GIS $6 million in damages. GIS then sought attorney’s fees from Guardian, while Guardian and RPM sought fees from GIS.The United States Court of Appeals for the Ninth Circuit reviewed the district court's award of over $4 million in attorney’s fees to GIS. The Ninth Circuit found that the district court correctly deemed GIS the prevailing party against Guardian, as GIS successfully defended against Guardian’s counterclaims and won significant damages. However, the Ninth Circuit held that the district court erred in its analysis of RPM’s entitlement to fees. The district court had deemed certain claims voluntarily dismissed, but the Ninth Circuit concluded that GIS did not provide adequate notice of its intent to abandon those claims. Therefore, the Ninth Circuit reversed the district court’s decision regarding the abandoned claims and remanded for further determination of fees due to RPM.The Ninth Circuit affirmed the district court’s methodology and equitable considerations in deeming GIS the prevailing party against Guardian but reversed and remanded the decision regarding RPM’s entitlement to fees. View "GPP, INC. V. GUARDIAN PROTECTION PRODUCTS, INC." on Justia Law

In the 1950s, the Tucson Unified School District (the District) operated a dual school system for Black and non-Black students. In 1974, class action lawsuits were filed on behalf of African American and Latino students, leading to a 1978 settlement agreement and desegregation decree. Over the years, the District undertook numerous efforts to remedy past discrimination. In 2011, the Ninth Circuit reversed a district court's preliminary finding of unitary status, remanding the case for further supervision. A Unitary Status Plan (USP) was created in 2013 to guide the District towards unitary status.The District Court for the District of Arizona found partial unitary status in 2018, retaining jurisdiction over unresolved issues. By 2021, the court found the District had achieved unitary status in most areas, except for two subsections of the USP. In 2022, after further revisions and compliance, the district court declared the District had achieved full unitary status and ended federal supervision.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's judgment. The Ninth Circuit held that the District had achieved unitary status, meaning it had complied in good faith with the desegregation decree and eliminated the vestiges of past discrimination to the extent practicable. The court found no error in the district court's conclusions regarding student assignments, transportation, staff diversity, quality of education, student discipline, family and community engagement, and transparency and accountability. The Ninth Circuit emphasized that perfect implementation of the USP was not necessary for unitary status and that the District had demonstrated a lasting commitment to the USP and the Constitution. View "MENDOZA V. TUCSON UNIFIED SCHOOL DISTRICT" on Justia Law

Shawn Sheltra, an inmate with the Idaho Department of Corrections (IDOC), filed a formal grievance in March, identifying safety concerns and threats from other inmates in his housing unit. He warned that he would be attacked in April if he did not make an extortion payment. Despite being briefly isolated, Sheltra was returned to his housing unit and was attacked by another inmate in April. He subsequently filed a lawsuit, asserting violations of the Eighth and Fourteenth Amendments due to the defendants' failure to protect him from a known harm.The United States District Court for the District of Idaho granted summary judgment for the defendants, dismissing the action for failure to exhaust administrative remedies because Sheltra did not file a formal grievance after the April attack. The court also granted summary judgment for the defendants on Sheltra's official-capacity claims, as they were barred by the Eleventh Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and adopted the continuing-violations doctrine for purposes of administrative exhaustion under the Prison Litigation Reform Act (PLRA). The court held that a properly exhausted prison grievance asserting one continuing harm or a single course of conduct can exhaust events arising out of the same alleged violation that occur after the grievance was made. Applying this doctrine, the court concluded that Sheltra's attack was part of the same continuing harm or course of conduct described in his prison grievance before the attack. Therefore, the court reversed the district court's summary judgment on Sheltra's individual-capacity claims against the defendants. However, the court affirmed the district court's grant of summary judgment for the defendants on Sheltra's official-capacity claims due to Eleventh Amendment immunity. View "SHELTRA V. CHRISTENSEN" on Justia Law

LegalForce RAPC Worldwide, P.C. ("LegalForce USA"), a California S corporation operating legal services websites, sued LegalForce, Inc. ("LegalForce Japan"), a Japanese corporation providing legal software services, for trademark infringement. LegalForce USA alleged that LegalForce Japan's U.S. expansion plans, website ownership, and advertising and selling of equity infringed its trademark. The district court dismissed the website claims for lack of jurisdiction and the expansion plan claims as unripe. The claims concerning equity were dismissed for failure to state a claim.The United States District Court for the Northern District of California dismissed all claims except those related to the advertising and selling of equity. The court held that it had jurisdiction over these claims but dismissed them for failure to state a claim, reasoning that advertising and selling equity is not connected to the sale of goods or services and thus cannot constitute trademark infringement. The court also found that LegalForce USA failed to justify an extraterritorial application of the Lanham Act.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that using a trademark in connection with the sale of equity does not constitute using the mark in connection with "goods or services" under the Lanham Act. The court also affirmed that LegalForce Japan's services in Japan could not satisfy the "in connection with" goods or services requirement under the Lanham Act, as the relevant conduct occurred outside U.S. territory. The court concluded that the Lanham Act does not apply extraterritorially in this context. View "LEGALFORCE RAPC WORLDWIDE, PC V. LEGALFORCE, INC." on Justia Law

Teradata Corporation sued SAP SE, alleging that SAP illegally conditioned sales of its business-management software (S/4HANA) on the purchase of its back-end database engine (HANA) in violation of Section 1 of the Sherman Act and misappropriated Teradata’s trade secrets under the California Uniform Trade Secrets Act. Teradata claimed that SAP’s tying arrangement forced customers to buy HANA, harming competition in the enterprise data warehousing (EDW) market. Teradata also alleged that SAP used its confidential batched merge method, a technique for efficient data aggregation, without authorization.The United States District Court for the Northern District of California granted summary judgment in favor of SAP. The court excluded Teradata’s expert testimony on market definition and market power, finding the methodology unreliable. Without this testimony, the court concluded that Teradata failed to create a material dispute on its tying claim. The court also ruled against Teradata on the trade secret claim, stating that Teradata did not properly designate the batched merge method as confidential and that the agreements between the parties gave SAP the right to use the method.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment. The appellate court held that the district court abused its discretion by excluding the expert’s testimony, which was based on reasonable methodologies. The court found that Teradata raised a triable issue regarding SAP’s market power in the tying market and the anticompetitive effects in the tied market. The court also determined that there were material factual disputes regarding whether Teradata properly designated the batched merge method as confidential and whether the agreements allowed SAP to use the method. The case was remanded for further proceedings. View "TERADATA CORPORATION V. SAP SE" on Justia Law