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

Articles Posted in Civil Rights
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The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

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The case involves a challenge to the constitutionality of private prisons in Arizona. The plaintiffs, the Arizona State Conference of the National Association for the Advancement of Colored People (NAACP) and two former prisoners, argued that private prisons, driven by profit, compromise safety and security and reduce programming and services. They also claimed that private prisons have a financial incentive to keep prisoners incarcerated longer by manipulating disciplinary proceedings.The United States District Court for the District of Arizona dismissed the case, leading to an appeal to the United States Court of Appeals for the Ninth Circuit. The district court held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights, the Thirteenth Amendment, the Eighth Amendment, and the Fourteenth Amendment's Equal Protection and Due Process Clauses.The Ninth Circuit affirmed the district court's decision. The court found that the NAACP had standing to bring the suit. However, it held that the plaintiffs failed to plausibly allege that private prisons violate prisoners' procedural due process rights. The court also found that the Thirteenth Amendment does not prohibit incarceration in a private prison, and that the plaintiffs failed to plausibly allege that confinement in a private prison violates the Eighth Amendment. Finally, the court held that the Fourteenth Amendment's Due Process and Equal Protection Clauses do not prohibit incarceration in a private prison. View "NIELSEN V. THORNELL" on Justia Law

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The plaintiff, Ronald Hittle, was the Fire Chief for the City of Stockton, California. He alleged that he was terminated from his position due to his religion, specifically his attendance at a religious leadership event. The City of Stockton, former City Manager Robert Deis, and former Deputy City Manager Laurie Montes were named as defendants. The City had hired an independent investigator, Trudy Largent, to investigate various allegations of misconduct against Hittle. Largent's report sustained almost all of the allegations, including Hittle's use of city time and a city vehicle to attend a religious event, his failure to properly report his time off, potential favoritism of certain Fire Department employees based on a financial conflict of interest not disclosed to the City, and endorsement of a private consultant's business in violation of City policy.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. The court also found that Hittle failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that employment discrimination claims under Title VII and the California Fair Employment and Housing Act are analyzed under the McDonnell Douglas burden-shifting framework. The court concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants. The court found that the district court's grant of summary judgment in the defendants' favor was appropriate where the defendants' legitimate, non-discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual. View "HITTLE V. CITY OF STOCKTON" on Justia Law

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Five registered gun owners in California challenged a state law, Assembly Bill 173 (AB 173), which permits the California Department of Justice (DOJ) to share information from its databases about firearm and ammunition purchasers and concealed carry weapon (CCW) permit holders with accredited research institutions. The plaintiffs argued that the law violated their right to informational privacy under the Fourteenth Amendment, their Second Amendment right to keep and bear arms, and the federal Privacy Act.The district court dismissed the case, finding that the plaintiffs failed to state a claim for violation of the right to informational privacy. The court reasoned that the personal information in the DOJ's databases was not highly sensitive or intimate and that the plaintiffs had no reasonable expectation that such information would never be disclosed. The court also found that AB 173 did not restrict conduct protected by the Second Amendment, as it did not impede the plaintiffs' ability to purchase, keep, carry, or use firearms. The court further held that AB 173 was not unconstitutionally retroactive, as it did not attach new legal consequences to past conduct. Finally, the court rejected the plaintiffs' claim that the Privacy Act preempted two California statutes relating to CCW permit applications, as neither statute required the disclosure of social security numbers.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision, agreeing with its findings and reasoning. The court held that the plaintiffs failed to state a claim for violation of the right to informational privacy, the Second Amendment, or the Privacy Act. View "JANE DOE V. BONTA" on Justia Law

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Diamond S.J. Enterprise, Inc., which operates a nightclub in San Jose, California, had its license suspended for thirty days by the city following a shooting outside the club. The city held an administrative hearing and found that Diamond had operated its venue in a way that caused the shooting and created a public nuisance, violating San Jose's entertainment business licensing provisions. Diamond filed a complaint in federal court, alleging First Amendment and due process violations.The case was first heard in the United States District Court for the Northern District of California, which dismissed Diamond's claims and granted summary judgment for the City of San Jose. The district court ruled that the challenged provisions did not implicate First Amendment rights and that the city had satisfied due process requirements.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's decision, holding that Diamond's facial attack on the city's public entertainment business licensing provisions failed because the provisions did not give city officials unbridled discretion that created a risk of censorship. The court also held that Diamond failed to state a procedural due process claim, as the licensing scheme provided Diamond with notice, an opportunity to be heard, the ability to present and respond to evidence, and a pre-deprivation appeal, followed by post-deprivation review by the California Superior Court. View "Diamond S.J. Enterprise, Inc. v. City of San Jose" on Justia Law

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The case involves a lawsuit filed by the family of Kyle Hart against the City of Redwood City and its police officers, following Hart's death in a police shooting. Hart, who was attempting suicide with a knife in his backyard, was shot by Officer Gomez when he approached the officers with the knife despite commands to drop it. The family alleged constitutional and state law violations arising from the shooting.The United States District Court for the Northern District of California denied Officer Gomez's claim of qualified immunity at summary judgment. The court found that the officer was not entitled to qualified immunity, relying on a previous court decision that stated it was objectively unreasonable to shoot an unarmed man who had committed no serious offense, was mentally or emotionally disturbed, had been given no warning of the imminent use of such a significant degree of force, posed no risk of flight, and presented no objectively reasonable threat to the safety of the officer or other individuals.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Officer Gomez was entitled to qualified immunity. The court found that Hart posed an immediate threat when he rapidly approached the officers brandishing a knife and refusing commands to drop it. Furthermore, even if Officer Gomez’s conduct violated the Fourth Amendment, he would still be entitled to qualified immunity because the conduct did not violate clearly established law. None of the cases the plaintiffs identified would have put Officer Gomez on notice that his actions in this case would be unlawful. View "Hart v. City of Redwood City" on Justia Law

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Matthew Meinecke, a devout Christian, was arrested twice by Seattle police for refusing to move from public locations where he was reading Bible passages. The first incident occurred at an abortion rally and the second at an LGBTQ pride event. In both instances, Meinecke was asked to move after attendees began to physically assault him. Instead of dealing with the perpetrators, the police arrested Meinecke for obstruction. Meinecke sued the City of Seattle and certain Seattle police officers, seeking to prevent them from enforcing "time, place, and manner" restrictions and applying the City’s obstruction ordinance to eliminate protected speech in traditional public fora whenever they believe individuals opposing the speech will act hostile toward it.The United States District Court for the Western District of Washington denied Meinecke's motion for preliminary injunctive relief, reasoning that the officers' actions were content neutral and did not aim to silence Meinecke. The court also expressed concern about the vague request for injunctive relief.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Meinecke has standing to pursue prospective injunctive relief, given that the City has twice enforced its obstruction ordinance against him, he has stated that he will continue his evangelizing efforts at future public events, and the City has communicated that it may file charges against him for doing so. The court found that Meinecke established a likelihood of success on the merits of his First Amendment claim. The restrictions on his speech were content-based heckler’s vetoes, where officers curbed his speech once the audience’s hostile reaction manifested. Applying strict scrutiny, the court held that there were several less speech-restrictive alternatives to achieve public safety, such as requiring protesters to take a step back, calling for more officers, or arresting the individuals who ultimately assaulted Meinecke. The court also held that Meineke established irreparable harm because a loss of First Amendment freedoms constitutes an irreparable injury, and the balance of equities and public interest favors Meinecke. The case was remanded with instructions to enter a preliminary injunction consistent with this opinion in favor of Meinecke. View "Meinecke v. City of Seattle" on Justia Law

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The case revolves around Victor Ramirez, who was pulled over by police officers for traffic violations. Recognizing Ramirez as a gang member from a previous encounter, one of the officers asked him about his parole status. Ramirez confirmed he was on parole for a firearm-related offense. During the stop, the officers discovered a loaded firearm in Ramirez's car. Ramirez was subsequently indicted for possessing a firearm and ammunition as a felon.Ramirez moved to suppress the gun and ammunition, arguing that the officers unreasonably prolonged the stop by asking about his parole status, which he claimed was unrelated to the traffic stop. The district court denied Ramirez's motion to suppress, and Ramirez pleaded guilty to possessing a firearm and ammunition as a felon, reserving his right to challenge the denial of his motion to suppress.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that asking about parole status during a traffic stop does not violate the Fourth Amendment as it reasonably relates to the officer's safety and imposes a negligible burden. The court also remanded the case in part so that the district court could correct the written judgment to conform it to the oral pronouncement of sentence. View "United States V. Ramirez" on Justia Law

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The case involves the family of Joseph Perez, who died after law enforcement officers, under the direction of a paramedic, used their body weight to restrain him while he was prone to secure him to a backboard for hospital transport. The family sued the City and County of Fresno, individual law enforcement officers, and the paramedic, alleging violations of the Fourth and Fourteenth Amendments and municipal liability under Monell v. Department of Social Services of the City of New York.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants, finding that the officers and paramedic were entitled to qualified immunity. The court held that at the time of Perez's death in 2017, the law did not clearly establish that the officers' actions would be unconstitutional. The court also found that the paramedic was entitled to qualified immunity because the law did not clearly establish that a paramedic acting in a medical capacity to restrain a person for medical transport could be held liable for a constitutional violation. The court dismissed the plaintiffs' Monell claims, finding insufficient evidence that the City and County were deliberately indifferent to their duty to properly train their officers.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the law did not clearly establish, nor was it otherwise obvious, that the officers' actions, directed by medical personnel, would violate Perez's constitutional rights. The court also held that the paramedic was acting in a medical capacity during the incident, and the law did not clearly establish that medical personnel are liable for constitutional torts for actions taken to provide medical care or medical transport. The court concluded that the plaintiffs produced insufficient evidence to support their municipal liability claim against the City and the County based on a failure-to-train theory. View "PEREZ V. CITY OF FRESNO" on Justia Law

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The case involves Adree Edmo, a transgender woman incarcerated in Idaho, who sued the State of Idaho, private prison company Corizon, and individual prison officials for failing to provide her with adequate medical care, including gender-confirmation surgery. Edmo alleged violations of the Eighth Amendment, the Fourteenth Amendment’s Equal Protection Clause, the Affordable Care Act, the Americans with Disabilities Act, and negligence under Idaho law. The district court granted an injunction on Edmo’s Eighth Amendment claim and ordered the defendants to provide her with adequate medical care, including gender-confirmation surgery. The court denied preliminary injunctive relief on Edmo’s Fourteenth Amendment and ACA claims because the record had not been sufficiently developed.The district court's decision was appealed, and the injunction was stayed. The Ninth Circuit Court of Appeals affirmed the district court’s decision except as it applied to five defendants in their individual capacities. After the Supreme Court denied a writ of certiorari, the parties engaged in settlement negotiations that led to Edmo voluntarily dismissing the remainder of her claims. The district court awarded Edmo $2,586,048.80 for attorneys’ fees incurred up until the injunction became permanent and all appeals were resolved.The Ninth Circuit Court of Appeals reversed in part, affirmed in part, and vacated in part the district court’s award of attorneys’ fees to Edmo. The court held that Edmo was entitled to fees incurred litigating her successful Eighth Amendment claim. However, the court found that the district court erred in calculating the lodestar amount to include fees incurred litigating unsuccessful claims advanced in the complaint, even if those claims were premised on the same facts that supported Edmo’s Eighth Amendment claim. The court also held that the district court did not err by applying an enhancement to the lodestar amount given that Edmo’s counsel operated under extraordinary time pressure and that the customary fee for counsel’s services is well above the PLRA cap. The case was remanded for recalculation of the lodestar amount to include only fees incurred litigating Edmo’s successful claim against the defendants who remained in the case. View "Edmo v. Corizon, Inc." on Justia Law