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

Claude Stephen Bent, a lawful permanent resident from Jamaica, pleaded no contest to two felony charges in California in 2006. The judge did not inform him of the immigration consequences of his plea. After serving his sentence, Bent was detained by the Department of Homeland Security (DHS) in 2016 and charged with removability based on his felony conviction. Bent applied for asylum and other relief, but an immigration judge (IJ) denied his application and ordered his removal. The Board of Immigration Appeals (BIA) affirmed the IJ's decision. Bent appealed to the Ninth Circuit, which remanded the case to the BIA. The BIA again dismissed his appeal, and Bent petitioned for review.Bent moved to vacate his 2006 conviction in California state court, which was granted in 2022 on the grounds that his plea was involuntary and violated his Fifth Amendment rights. Bent then moved to reopen his removal proceedings before the BIA, arguing that his vacated conviction invalidated the basis for his removal. The BIA denied the motion, stating it was untimely and not subject to equitable tolling, and mischaracterized the California statute as allowing vacatur solely to mitigate immigration consequences.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court found that the BIA erred in its interpretation of California Penal Code § 1473.7(a)(1) and the state court's order, which vacated Bent's conviction due to a constitutional defect, not to alleviate immigration consequences. The Ninth Circuit also held that the BIA misapplied equitable tolling precedent by not properly assessing whether Bent diligently pursued his rights. The court granted Bent's petition for review in part and remanded the case to the BIA to adjudicate his motion to reopen under the correct legal standards. View "BENT V. GARLAND" on Justia Law

In this case, the plaintiffs, Election Integrity Project California, Inc., and ten former political candidates, challenged the California Secretary of State’s certification of the November 2020 general election results and sought to declare California’s vote-by-mail election system unconstitutional. They alleged that state and county officials diluted the voting power of in-person voters and voters in certain counties by inadvertently counting some invalid vote-by-mail ballots.The United States District Court for the Central District of California dismissed the plaintiffs’ claims for failure to state a claim. The district court concluded that even if all the plaintiffs’ allegations were true, they failed to state plausible claims of constitutional violations in the administration of California’s elections. The plaintiffs appealed the dismissal.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 the plaintiffs’ vote dilution claim failed as a matter of law because they did not show disproportionate voting power for some voters over others. The court found that any effect of counting invalid vote-by-mail ballots was the same for all votes, regardless of voting method or geography. The court also rejected the plaintiffs’ claim that California’s election laws and county practices violated the Equal Protection Clause, finding that the state’s election rules and practices satisfied the requirements of equal treatment and fundamental fairness. Additionally, the court found that the plaintiffs’ allegations of election irregularities did not plausibly demonstrate the scale of disenfranchisement or lack of integrity necessary to state a due process claim.Finally, the Ninth Circuit held that the district court did not abuse its discretion by denying the plaintiffs a further opportunity to amend their complaint, as any further amendment would likely prove futile. The court affirmed the district court’s order dismissing the plaintiffs’ claims without leave to amend. View "ELECTION INTEGRITY PROJECT CALIFORNIA, INC. V. WEBER" on Justia Law

Maria Pomares submitted three Freedom of Information Act (FOIA) requests to the Department of Veterans Affairs (VA) concerning potential misconduct within the VA. She suspected that Charmain Bogue, the director of the Education Service in the Veterans Benefit Administration, had improper ties to a political advocacy organization and that the VA might have leaked nonpublic information. After Pomares submitted her FOIA requests, the VA’s Office of Inspector General (OIG) found that Bogue had acted improperly.The United States District Court for the Southern District of California granted summary judgment in favor of the VA. The court concluded that the VA’s search for responsive emails was reasonable and that the VA properly justified its withholdings under FOIA Exemptions 4, 5, 6, and 7. The district court found that the Vaughn Indices provided by the VA were adequate and included sufficient detail to justify the withholdings.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s judgment regarding the adequacy of the VA’s search for emails and the application of Exemption 4 to records obtained from Evocati. The court also affirmed the application of Exemption 6 to the redaction of names and contact information, except for the names (but not email addresses) of Veterans Education Success (VES) employees who lobbied Congress or the VA. However, the court reversed the district court’s judgment regarding the withholding of OIG interview transcripts under Exemption 7(E), as the VA did not adequately justify that the interview techniques and methods used by OIG fell within this exemption. The case was remanded for further proceedings consistent with the opinion. View "Pomares v. USDVA" on Justia Law

Ryan Cox filed a class action lawsuit alleging that the defendants manipulated the price of a cryptocurrency called HEX by artificially lowering its ranking on CoinMarketCap.com. The defendants include two domestic companies, a foreign company, and three individual officers of the foreign company. Cox claimed that the manipulation caused HEX to trade at lower prices, benefiting the defendants financially.The United States District Court for the District of Arizona dismissed the case for lack of personal jurisdiction, concluding that Cox needed to show the defendants had sufficient contacts with Arizona before invoking the Commodity Exchange Act's nationwide service of process provision. The court found that none of the defendants had sufficient contacts with Arizona.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the Commodity Exchange Act authorizes nationwide service of process independent of its venue requirement. The court concluded that the district court had personal jurisdiction over the U.S. defendants, CoinMarketCap and Binance.US, because they had sufficient contacts with the United States. The court also found that Cox's claims against these defendants were colorable under the Commodity Exchange Act. Therefore, the court reversed the district court's dismissal of the claims against the U.S. defendants and remanded for further proceedings.However, the Ninth Circuit affirmed the district court's dismissal of the claims against the foreign defendants, Binance Capital and its officers, due to their lack of sufficient contacts with the United States. The court vacated the dismissal "with prejudice" and remanded with instructions to dismiss the complaint against the foreign defendants without prejudice. View "COX V. COINMARKETCAP OPCO, LLC" on Justia Law

The case involves a non-fatal shooting of Joseph Williams by officers of the Sparks Police Department following a 42-minute car chase. Williams had stolen alcohol and vandalized a vehicle, leading to a police pursuit. During the chase, Williams ran red lights, drove through a fence, and briefly drove on the wrong side of the freeway. The chase ended when officers pinned Williams's truck, but he continued to attempt to flee, leading officers to fire multiple rounds, injuring him.The United States District Court for the District of Nevada denied summary judgment on Williams's claims of excessive force, municipal liability, and battery, except for the negligence claim. The court found genuine factual disputes about the threat Williams posed and whether he was attempting to flee when officers fired. The court also denied summary judgment on the Monell claims and the battery claim, citing unresolved factual issues.The United States Court of Appeals for the Ninth Circuit reversed the district court's denial of summary judgment. The appellate court found that video evidence clearly showed Williams attempting to accelerate, contradicting his claim. The court held that the officers' use of deadly force was objectively reasonable, given the threat Williams posed to public safety. The court also exercised pendent jurisdiction over the Monell and battery claims, finding no constitutional violation in the officers' use of force and ruling that the battery claim failed because the force used was not unreasonable. The court reversed and remanded the case for further proceedings consistent with its opinion. View "Williams v. City of Sparks" on Justia Law

La Dell Grizzell, acting on behalf of her minor children, sued San Elijo Elementary School and the San Marcos Unified School District, alleging that the school violated her children's federal and state civil rights. The complaint included claims of racial discrimination and other civil rights violations, such as racial epithets, physical assaults, and discriminatory disciplinary measures. Grizzell sought to proceed without legal representation.The United States District Court for the Southern District of California dismissed the case without prejudice, citing the "counsel mandate," which precludes nonlawyer parents from representing their children pro se. The court emphasized that regardless of the merits of the case, Grizzell could not represent her children without an attorney. The district court instructed that the minor plaintiffs could only proceed through a licensed attorney.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 it was bound by its precedent in Johns v. County of San Diego, which prohibits nonattorney parents from representing their children in court. Despite Grizzell's arguments that this rule impedes access to justice for children from low-income families, the panel concluded that it could not deviate from established precedent. The court acknowledged the serious implications of the counsel mandate but affirmed the dismissal without prejudice, indicating that only en banc review could potentially alter the rule. View "GRIZZELL V. SAN ELIJO ELEMENTARY SCHOOL" on Justia Law

The case involves a consumer class action against Premier Nutrition Corporation, which marketed Joint Juice, a dietary supplement drink, as effective for relieving joint pain. Mary Beth Montera, representing a class of New York consumers, alleged that Premier's advertising was deceptive and violated New York General Business Law (GBL) §§ 349 and 350. These laws require proof that the defendant engaged in consumer-oriented conduct that was materially misleading and caused injury to the plaintiff.The United States District Court for the Northern District of California certified the class and the case proceeded to trial. Montera presented evidence, including studies showing that Joint Juice's key ingredients, glucosamine and chondroitin, were ineffective for joint health. Premier countered with industry-funded studies supporting the product's efficacy. The jury found Premier's statements deceptive and awarded statutory damages based on the number of units sold in New York during the class period. Premier's post-trial motions to decertify the class and for judgment as a matter of law were denied.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court's rulings on class certification, liability under GBL §§ 349 and 350, and the initial calculation of statutory damages. The court rejected Premier's arguments that its statements were not materially misleading and that Montera's injury was not cognizable under New York law. The court also upheld the jury's finding that the class members' injuries were caused by Premier's misrepresentations.However, the Ninth Circuit vacated the district court's award of prejudgment interest, ruling that statutory damages under GBL §§ 349 and 350 are not compensatory and thus do not warrant prejudgment interest. The court also remanded the case for the district court to reconsider the statutory damages award in light of the factors identified in Wakefield v. ViSalus, Inc., which addresses the substantive due process limits on aggregate statutory damages. The court affirmed in part, reversed in part, and vacated and remanded in part. View "MONTERA V. PREMIER NUTRITION CORPORATION" on Justia Law

John Doe, a detained alien, filed a habeas corpus petition under 28 U.S.C. § 2241 in the Northern District of California, challenging his detention at the Golden State Annex (GSA) in the Eastern District of California. He named several federal officials, including the Attorney General and the Acting Director for the San Francisco ICE Field Office, as respondents. Doe sought release unless he was provided a bond hearing. The district court granted Doe’s petition, leading to his release after a bond hearing.The district court denied the respondents' motion to dismiss, which argued that the court lacked jurisdiction because Doe did not name his immediate custodian and filed the petition outside the district of confinement. The court held that the Northern District of California was an appropriate jurisdiction for petitions filed by aliens detained by the San Francisco ICE Field Office.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The Ninth Circuit held that the district court erred in exercising jurisdiction over Doe’s habeas petition. The court explained that under Rumsfeld v. Padilla, a core habeas petition challenging present physical confinement must name the immediate custodian, typically the warden, and be filed in the district of confinement. Doe’s petition was a core habeas petition because it sought release from detention. However, Doe failed to name the Facility Administrator of GSA as the respondent and filed the petition in the Northern District of California instead of the Eastern District of California, where he was confined. Consequently, the Ninth Circuit reversed the district court’s denial of the motion to dismiss and remanded with instructions to vacate the grant of Doe’s habeas petition. View "DOE V. GARLAND" on Justia Law

The plaintiffs, EB Holdings II, Inc. and QXH II, Inc., sought coverage from their insurers for legal fees and expenses incurred in defending against a lawsuit alleging fraudulent inducement in the purchase of notes backed by their long-term debt. The insurers denied coverage, claiming the plaintiffs made material misrepresentations in their insurance renewal application by failing to disclose significant long-term debt.The United States District Court for the District of Nevada granted summary judgment in favor of the insurers, concluding that Nevada law governed the affirmative defense of material misrepresentation. The court found that the plaintiffs had indeed made a material misrepresentation by not disclosing their long-term debt, thus barring coverage under the insurance policies.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's decision. The appellate court held that the district court erred in its choice-of-law analysis. The Ninth Circuit determined that Texas law, not Nevada law, should govern the affirmative defense of material misrepresentation. The court reasoned that the substantial relationship test set forth in the Restatement (Second) of Conflict of Laws § 188 pointed to Texas law, given that the underwriting process largely occurred through agents based in Texas and the plaintiffs were headquartered there.Applying Texas law, the Ninth Circuit found that there were material disputes of fact regarding the elements of the affirmative defense, including the plaintiffs' intent to deceive and whether the insurers provided timely notice of their refusal to be bound by the policy. Consequently, the court reversed the summary judgment and remanded the case to the district court for further proceedings. View "EB HOLDINGS II, INC. V. ILLINOIS NATIONAL INSURANCE COMPANY" on Justia Law

The case involves a coalition of states led by Washington suing the FDA over its 2023 REMS, which eliminated in-person dispensing requirements for the abortion drug mifepristone. Washington argues that the FDA should have further reduced restrictions on the drug, claiming that the remaining requirements impose unnecessary hurdles. Idaho, leading another coalition of states, sought to intervene, arguing that the elimination of the in-person dispensing requirement would harm its interests by making the drug easier to obtain and harder to police, potentially increasing Medicaid costs and endangering maternal health and fetal life.The United States District Court for the Eastern District of Washington denied Idaho's motion to intervene. The court found that Idaho did not have a significantly protectable interest that would be impaired by the litigation, as its complaint concerned different aspects of the 2023 REMS. The court also denied permissive intervention, concluding that Idaho's claims did not share common questions of law or fact with Washington's claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's denial of Idaho's motion to intervene as of right. The Ninth Circuit held that Idaho must independently satisfy the requirements of Article III standing because it sought different relief from Washington. The court concluded that Idaho's complaint did not establish a cognizable injury-in-fact that was fairly traceable to the FDA's revised safe-use restrictions. Idaho's alleged economic injuries, law enforcement burdens, and quasi-sovereign interests were deemed too speculative or indirect to confer standing. The court dismissed for lack of jurisdiction the portion of the appeal concerning the denial of permissive intervention. View "STATE OF WASHINGTON V. FDA" on Justia Law