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

Vietnamese refugees and residents of San Diego County, Anh Thai and Don Doan, alleged that two law enforcement officers, Dulce Sanchez and William Villasenor, violated their constitutional rights by forcibly entering their homes and interrogating them about their disability benefits. Sanchez and Villasenor were Los Angeles District Attorney’s Office investigators assigned full-time to a joint federal-state task force, the Cooperative Disability Investigations (CDI) Unit, which investigates fraud in Social Security disability benefits applications. The plaintiffs claimed that the officers displayed guns and state badges, did not seek consent for the search, and failed to have an interpreter present during the investigations.The United States District Court for the Southern District of California granted summary judgment in favor of Sanchez and Villasenor, concluding that the officers were acting under color of federal law, not state law, and therefore could not be held liable under 42 U.S.C. § 1983. The district court found that the CDI Unit was implemented under federal authority, and the officers’ day-to-day work was supervised by a federal officer, Special Agent Glenn Roberts.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that because the CDI Unit was created under federal authority and supervised by a federal officer, Sanchez and Villasenor were acting under color of federal law. The court noted that the officers’ paychecks were reimbursed by the Social Security Administration, and their investigations took place outside of Los Angeles County, further indicating their federal role. Consequently, the officers were not subject to suit under § 1983, which applies to actions under color of state law. The court affirmed the district court’s summary judgment in favor of the defendants. View "Thai v. County of Los Angeles" on Justia Law

A high school student, K.J., was involved in a fight on campus and was initially suspended for three days. After reviewing surveillance footage and learning about injuries sustained during the fight, school officials extended K.J.'s suspension and recommended his expulsion, without informing him of the new charges or evidence. K.J. was not given an opportunity to respond to these new allegations.The United States District Court for the Southern District of California found that the school officials violated K.J.'s procedural due process rights by not informing him of the new charges or evidence. However, the court granted summary judgment in favor of the defendants, holding that they were entitled to qualified immunity because the law was not clearly established regarding due process protections for suspension extensions. The court also held that K.J. lacked standing to seek expungement of his disciplinary record, as it was speculative that the record would harm his reputation or future prospects.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment. The Ninth Circuit agreed that K.J.'s due process rights were violated, as he was not given notice of the new charges or an opportunity to respond. The court held that the defendants were not entitled to qualified immunity because the requirements for due process in school suspensions were clearly established in Goss v. Lopez. The court also held that K.J. had standing to seek expungement of his disciplinary record and that such relief was not barred by Eleventh Amendment sovereign immunity. The case was remanded to the district court to consider K.J.'s claims for damages and expungement. View "K. J. V. JACKSON" 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 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

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

Krish Singh was shot and seriously injured by Officer Brittany Smith-Petersen in Phoenix, Arizona. Smith-Petersen and another officer, Annie Batway, responded to a report of an attempted robbery with a knife. Upon arrival, Singh held a knife to his own neck and asked the officers to shoot him. Despite commands to drop the knife, Singh did not comply, and Smith-Petersen shot him. Singh sued the City of Phoenix, Smith-Petersen, and Batway, alleging excessive force under 42 U.S.C. § 1983 and various state law claims.The United States District Court for the District of Arizona granted summary judgment in favor of Smith-Petersen on the § 1983 claim, holding that she was protected by qualified immunity. The court found that although a reasonable jury could find a constitutional violation, there was no clearly established law indicating that her use of force was objectively unreasonable. The district court remanded the state law claims to state court for resolution.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment on the § 1983 claim, holding that the case of Glenn v. Washington County, which involved similar facts, provided clearly established law that should have put Smith-Petersen on notice that her use of deadly force was potentially unreasonable. The Ninth Circuit also reversed the district court’s order remanding the state law claims and remanded for reconsideration of whether to exercise supplemental jurisdiction over those claims. The court dismissed Smith-Petersen’s cross-appeal for lack of jurisdiction, as it challenged the district court’s determination of genuine factual disputes, which is not reviewable on appeal. View "SINGH V. CITY OF PHOENIX" on Justia Law

Steven Catlin, a California state prisoner, appealed the district court’s denial of his 28 U.S.C. § 2254 habeas corpus petition challenging his 1990 conviction for the murders of his fourth wife, Joyce Catlin, and his adoptive mother, Martha Catlin, as well as his death sentence. Catlin was convicted of murdering three family members with paraquat, a poisonous herbicide. The habeas petition in this case relates to his convictions for the murders of Joyce and Martha and the death sentence for Martha’s murder.The California Supreme Court (CSC) summarily denied Catlin’s first state habeas petition on the merits in 2007 and rejected his second state habeas petition in 2013 as procedurally barred. The district court denied Catlin’s federal habeas petition and his motion for discovery and evidentiary development in 2019, granting a certificate of appealability on several claims.The United States Court of Appeals for the Ninth Circuit reviewed Catlin’s claims under the deferential standard set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Catlin’s habeas petition, concluding that the CSC reasonably rejected Catlin’s claims. The court held that the CSC acted reasonably in rejecting Catlin’s claims of error arising from the state trial judge’s ex parte discussion with a juror, concluding that there was no ineffective assistance of counsel at both the guilt and penalty phases of Catlin’s trial, and determining that there was no violation of due process rights under Brady v. Maryland and Napue v. Illinois.The Ninth Circuit also declined to issue a certificate of appealability for Catlin’s uncertified claim that the state violated his due process rights by withholding exculpatory evidence and presenting false evidence. The court found that no reasonable jurist could debate the district court’s resolution of this claim. View "CATLIN V. BROOMFIELD" on Justia Law