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

A prison inmate with a documented history of mobility impairments and medical accommodations, including the use of a wheelchair and a transportation code requiring wheelchair-accessible vehicles, was scheduled for transfer between two facilities. On the day of the transport, he arrived in his wheelchair but was not provided with an accessible van. Instead, prison officials attempted to move him onto a standard bus. The inmate protested, stating he could not board without proper accommodations, but officials treated his protest as a refusal. After a crisis negotiator was called and negotiations failed, prison staff physically moved him onto the bus, allegedly causing him injury.A magistrate judge in the United States District Court for the Western District of Washington found that there were genuine disputes of material fact regarding the officials’ awareness of the inmate’s needs, the transportation code in effect, the extent of force used, and the resulting injuries. The magistrate recommended denying summary judgment and qualified immunity for most defendants. However, the district court rejected these recommendations, granted summary judgment for the State of Washington and the individual prison officials, and found that qualified immunity shielded the officials, reasoning that the mistaken transportation code did not amount to deliberate indifference.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the district court erred in granting summary judgment because material factual disputes remained regarding whether officials had notice of the inmate’s need for accommodation and the extent of their investigation into those needs. The Ninth Circuit also found that these disputes precluded summary judgment on Eighth Amendment claims alleging deliberate indifference and excessive force, and that qualified immunity was improperly granted at this stage. The court reversed the district court’s judgment and remanded for further proceedings. View "WELDEYOHANNES V. STATE OF WASHINGTON" on Justia Law

A computer science teaching professor at a public university included a statement in his course syllabus that parodied the university’s recommended indigenous land acknowledgment. This statement, which challenged the university’s view regarding the ownership of campus land, drew complaints from students and staff, particularly those involved in diversity and indigenous advocacy. The professor refused to remove the statement when asked, prompting university administrators to replace his syllabus, publicly condemn his remarks, and encourage official complaints from students. The university then initiated a lengthy disciplinary investigation, withheld a merit pay increase during this period, issued a reprimand, and warned of potential future discipline if the professor continued similar conduct. The university’s actions were based on the disruption and distress reported by students and concerns about creating an unwelcome environment.The United States District Court for the Western District of Washington found that the professor’s speech was protected and addressed a matter of public concern. However, applying the balancing test from Pickering v. Board of Education, it granted summary judgment to the university, finding that the institution’s interest in preventing disruption and maintaining an inclusive learning environment outweighed the professor’s First Amendment rights. The district court also dismissed the professor’s facial challenges to the university’s nondiscrimination policy, interpreting it narrowly to apply only to conduct resembling unlawful discrimination, harassment, or retaliation.The United States Court of Appeals for the Ninth Circuit reversed the district court’s grant of summary judgment for the university and directed that summary judgment be entered for the professor on his First Amendment retaliation and viewpoint discrimination claims. The appellate court held that the professor’s syllabus statement was protected academic speech on a matter of public concern, and that student or community offense or discomfort could not justify university retaliation or discipline under the First Amendment. The panel also ruled that the district court improperly construed the university’s nondiscrimination policy and remanded for further proceedings on the policy’s facial constitutionality. View "REGES V. CAUCE" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

Several individuals, representing a class, challenged a health insurance company’s refusal to cover gender-affirming care for transgender individuals diagnosed with gender dysphoria. The company, acting as a third-party administrator for employer-sponsored, self-funded health plans, denied coverage for such treatments based on explicit plan exclusions requested by the employer sponsors. Some plaintiffs also alleged that they were denied coverage for treatments that would have been covered for other diagnoses, such as precocious puberty, but were denied solely because of the concurrent diagnosis of gender dysphoria.The United States District Court for the Western District of Washington certified the class and granted summary judgment in favor of the plaintiffs. The district court rejected the company’s arguments that it was not subject to Section 1557 of the Affordable Care Act because its third-party administrator activities were not federally funded, that it was merely following employer instructions under ERISA, and that it was shielded by the Religious Freedom Restoration Act (RFRA). The district court also found that the exclusions constituted sex-based discrimination under Section 1557.On appeal, the United States Court of Appeals for the Ninth Circuit agreed with the district court that the company is subject to Section 1557, that ERISA does not require administrators to enforce unlawful plan terms, and that RFRA does not provide a defense in this context. However, the Ninth Circuit held that the district court’s analysis of sex-based discrimination was undermined by the Supreme Court’s intervening decision in United States v. Skrmetti, which clarified the application of sex discrimination standards to exclusions for gender dysphoria treatment. The Ninth Circuit vacated the summary judgment and remanded the case for further proceedings to consider whether, under Skrmetti, the exclusions at issue may still constitute unlawful discrimination, particularly in cases involving pretext or proxy discrimination or where plaintiffs had other qualifying diagnoses. View "PRITCHARD V. BLUE CROSS BLUE SHIELD OF ILLINOIS" on Justia Law

A 12-year-old boy was killed by police officers during an attempt to rescue him from a neighbor who had already killed the boy’s mother and housekeeper, gravely wounded his sister, and was holding the boy hostage in a vehicle. The officers responded to multiple 911 calls, surrounded the vehicle, and attempted to negotiate with the hostage-taker, who was armed and making threats against the child’s life. After the hostage-taker was shot and killed by an officer, other officers fired additional shots, which resulted in the boy’s death.The boy’s father, siblings, and estate filed a lawsuit in the United States District Court for the District of Nevada against the city, police department, and individual officers. They alleged violations of the Fourth Amendment (excessive force), Fourteenth Amendment (substantive due process), a Monell claim for failure to train, and state law claims. The district court dismissed the federal claims with prejudice, finding that the officers had not seized the boy for Fourth Amendment purposes, had not acted with deliberate indifference or intent to harm for Fourteenth Amendment purposes, and that the Monell claim failed in the absence of a constitutional violation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the officers did not violate the boy’s Fourth Amendment rights because their actions during the active hostage situation did not constitute a seizure, and even if a violation had occurred, qualified immunity would apply as the right was not clearly established. The court also found no Fourteenth Amendment violation, as the officers’ actions did not shock the conscience or demonstrate deliberate indifference, and qualified immunity would apply. The Monell claim failed due to the absence of an underlying constitutional violation. View "HAWATMEH V. CITY OF HENDERSON" on Justia Law

An armed fugitive fleeing law enforcement entered a print shop owned by the plaintiff, forcibly removed him, and barricaded himself inside. After a thirteen-hour standoff, Los Angeles Police Department SWAT officers used dozens of tear gas canisters to subdue the fugitive, causing significant damage to the shop and its contents. The parties agreed that the officers’ actions were authorized, reasonable, and lawful. The plaintiff alleged that the damages, which exceeded $60,000, were caused exclusively by the police.The plaintiff initially sought compensation from the United States Marshals Service, which denied the claim and referred him to the City of Los Angeles. After the City did not respond to his claims or his attorney’s letter, the plaintiff filed a federal lawsuit under 42 U.S.C. § 1983, asserting a violation of the Fifth Amendment’s Takings Clause. The City moved for judgment on the pleadings, arguing that the Takings Clause does not require compensation for property destroyed by police acting reasonably in an emergency. The United States District Court for the Central District of California denied the City’s initial motion but later granted summary judgment for the City, finding that the destruction was a valid exercise of police power and not a compensable taking.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The court held that the government’s destruction of private property, when necessary and reasonable for public safety, is exempt from the Takings Clause. The court relied on historical understanding and longstanding precedent, concluding that such actions fall outside the scope of the Takings Clause. Accordingly, the Ninth Circuit affirmed the district court’s judgment, holding that the plaintiff failed to state a claim for a compensable taking under the Fifth Amendment. View "PENA V. CITY OF LOS ANGELES" on Justia Law

A man with a prosthetic leg and wheelchair mobility visited a 7-Eleven store in California and encountered physical barriers that made access from the parking lot to the store entrance difficult. Specifically, the van-accessible parking was occupied, forcing him to park elsewhere and navigate a curb ramp with an excessive and uneven slope, which caused him difficulty and fatigue. After making a purchase, he filed suit against 7-Eleven under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act, alleging discrimination due to the store’s failure to remove architectural barriers where removal was readily achievable.The United States District Court for the Eastern District of California held a bench trial. The court found that, during his visits, the plaintiff personally encountered several violations of the ADA Accessibility Guidelines related to the route from accessible parking to the store entrance. After the lawsuit was filed, 7-Eleven voluntarily remodeled the parking lot and entryway to comply with ADA standards, which mooted the plaintiff’s claim for injunctive relief under the ADA. However, the court determined that a violation of the ADA also constituted a violation of the Unruh Act and awarded the plaintiff $4,000 in statutory damages.The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s judgment, holding that Title III of the ADA requires removal of architectural barriers where such removal is readily achievable, and that the defendant bears the ultimate burden of proving removal is not readily achievable. The court found that 7-Eleven’s voluntary remediation demonstrated that removal was readily achievable. The court also held that a plaintiff who personally encounters an ADA violation while transacting with a business has standing under the Unruh Act, regardless of litigation motive or intent to be a customer. The case was remanded for issues related to the substitution of the plaintiff’s successors. View "GILBERT V. 7-ELEVEN, INC." on Justia Law

Isaac Contreras, a criminally committed patient at the Arizona State Hospital, was confined in an isolation cell for 665 days under the hospital’s “Administrative Separation” policy after a series of behavioral incidents. Emmanuel Walker, acting as Contreras’s guardian, filed suit in Arizona Superior Court against the State of Arizona and several officials, alleging that Contreras’s confinement violated his rights under both state and federal law. The complaint included two federal claims under 42 U.S.C. § 1983 and five state law claims, including one under Arizona Revised Statutes § 36-516, which protects the rights of seriously mentally ill persons.After the case was removed to the United States District Court for the District of Arizona based on federal question jurisdiction, the State moved for judgment on the pleadings on the § 36-516 claim. The district court granted the motion, dismissing that claim, and did not enter partial judgment under Rule 54(b). To expedite appellate review of this dismissal, the parties jointly stipulated to dismiss all remaining claims, both state and federal, with prejudice. The district court then dismissed the entire case, and Walker appealed the dismissal of the state law claim.While the appeal was pending, the Supreme Court decided Royal Canin U.S.A., Inc. v. Wullschleger, which held that if a plaintiff eliminates all federal claims after removal, the federal court loses jurisdiction and must remand the case to state court. The United States Court of Appeals for the Ninth Circuit held that a joint stipulation of dismissal functions the same as an amendment for jurisdictional purposes. The court concluded that the district court lost jurisdiction before entering final judgment and was required to remand the remaining state law claim to the Arizona Superior Court. The Ninth Circuit remanded the case to the district court with instructions to reopen and remand the state law claim. View "WALKER V. STATE OF ARIZONA" on Justia Law

A prisoner at Kern Valley State Prison was involved in a disputed physical altercation with two correctional officers. The prisoner alleged that the officers used excessive force against him, while the officers claimed the prisoner initiated the altercation. After the incident, the prisoner was found guilty at a prison disciplinary hearing and later filed a pro se lawsuit under 42 U.S.C. § 1983, alleging Eighth Amendment violations. Over a year after the incident, the state charged the prisoner with battery and resisting an executive officer. The prisoner ultimately entered a nolo contendere plea to the resisting charge, expressing concern that the plea might affect his civil case.The United States District Court for the Eastern District of California initially denied the officers’ motion for judgment on the pleadings, finding that the prisoner’s nolo plea was inadmissible under Federal Rule of Evidence 410(a). However, after a change in presiding judge, the court reconsidered and granted the officers’ motion, holding that the nolo plea could be considered and that the prisoner’s civil suit was barred by Heck v. Humphrey, because success in the civil suit would necessarily imply the invalidity of the criminal conviction.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that, in a § 1983 action where the Heck bar is at issue, a plaintiff’s nolo contendere plea is inadmissible under Federal Rule of Evidence 410(a) to show that the plaintiff committed the charged crime. The court concluded that neither the plea nor statements made during the plea proceedings should have been admitted against the plaintiff in the civil case. The case was remanded for further proceedings. View "KING V. VILLEGAS" on Justia Law

A group of more than 80 former at-will employees of a nonprofit healthcare system in Washington were terminated after refusing to comply with a COVID-19 vaccination mandate issued by their employer, which was in response to an August 2021 proclamation by the state’s governor requiring healthcare workers to be vaccinated. The employees alleged that, at the time, only an “investigational” vaccine authorized for emergency use was available, and they claimed their rights were violated when they were penalized for refusing it. They also argued they were not adequately informed of their right to refuse the vaccine.The United States District Court for the Western District of Washington first dismissed all claims against the governor, then dismissed the federal claims against the healthcare system, and denied the employees’ motions for leave to amend and reconsideration. The district court also declined to exercise supplemental jurisdiction over the remaining state-law claims against the healthcare system.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 none of the employees’ statutory or non-constitutional claims, which were based on various federal statutes, regulations, agreements, and international treaties, alleged specific and definite rights enforceable under 42 U.S.C. § 1983. The court also found that the employees’ constitutional claims failed: the Fourteenth Amendment substantive due process claim was foreclosed by Jacobson v. Massachusetts and Health Freedom Defense Fund, Inc. v. Carvalho; the procedural due process claim failed because at-will employment is not a constitutionally protected property interest; and the equal protection claim failed because the mandate survived rational-basis review. The court further held that amendment of the federal claims would be futile and upheld the district court’s dismissal of the state law claims against the governor and its decision to decline supplemental jurisdiction over the state law claims against the healthcare system. View "Curtis v. Inslee" on Justia Law