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

Defendant was convicted of first-degree murder, conspiracy to commit murder, and kidnapping. Defendant was sentenced to death. Defendant subsequently petitioned for a writ of habeas corpus in federal district court. The district court denied the appeal. On remand to the district court from a prior decision of the Ninth Circuit Court of Appeals, Defendant contended his counsel was ineffective for presenting evidence at his sentencing hearing that he had suffered four head injuries and that these injuries affected his mental functions at the time of the murder. The Ninth Circuit affirmed the district court's order denying Defendant's petition for writ of habeas corpus, holding that the district court did not abuse its discretion in finding that Defendant was not prejudiced by his counsel's failure to submit this additional evidence. View "Scott v. Ryan" on Justia Law

Plaintiff, a former employee of the Equal Employment Opportunity Commission (EEOC) who suffered from multiple sclerosis and systemic lupus, filed an administrative complaint based on alleged violations of the Rehabilitation Act of 1973. The complaint was adjudicated by an ALJ, who denied relief in part. Plaintiff then filed an optional administrative appeal with the EEOC. Plaintiff withdrew her appeal without waiting 180 days as specified in 29 C.F.R. 1614.407(d) and filed suit in district court based on the same claims she asserted in her administrative complaint. The district court dismissed Plaintiff's complaint for failure to exhaust administrative remedies, holding that under Rivera v. USPS, it lacked jurisdiction because Plaintiff had not waited 180 days after filing her administrative appeal. The Ninth Circuit Court of Appeals reversed, holding that based on Bankston v. White and on post-Rivera regulation, Bullock had exhausted her administrative remedies. Remanded. View "Bullock v. Berrien" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder. This case was the second time Defendant sought habeas review in the Ninth Circuit Court of Appeals. In 2008, the Ninth Circuit affirmed the district court's denial of Defendant's first habeas petition. The State of Arizona subsequently issued a death warrant and set August 8, 2012 as Cook's execution date. Here Defendant asserted that his pretrial was ineffective and that his postconviction relief (PCR) counsel was ineffective. Defendant argued that the U.S. Supreme Court's decision in Martinez v. Ryan required the district court to excuse his procedural default because of ineffective assistance of counsel (IAC) in his state PCR proceedings. Defendant also asked the Court to stay his execution so he could further pursue his underlying pretrial IAC claim. The Ninth Circuit (1) affirmed the district court's decision to deny Defendant's Fed. R. Civ. P. 60(b)(6) motion for relief for judgment under Martinez, holding that Martinez does not apply to this case; and (2) denied Defendant's motion for a stay of execution, as Defendant's pretrial IAC claim lacked merit. View "Cook v. Ryan" on Justia Law

Defendant Rufino Valdes-Vega appealed the district court's denial of his motion to suppress cocaine found in his truck. Defendant contended that the stop of his truck by border patrol agents seventy miles north of the U.S.-Mexico border violated the Fourth Amendment, and consequently, the cocaine found in his truck must be suppressed. The Ninth Circuit Court of Appeals agreed and reversed the district court's denial of Defendant's motion to suppress, holding that the totality of the circumstances in this case did not provide border patrol agents with reasonable suspicion to believe that Defendant was smuggling drugs or aliens. View "United States v. Valdes-Vega" on Justia Law

Marc and Claire Headley were two former ministers of the Church of Scientology International. Marc sued the Church and Claire sued the Church and the Religious Technology Center under the Trafficking Victims Protection Act (Act), making claims of forced labor and that the Church and Center psychologically coerced them to provide labor. Specifically, they contended that the Church and Center violated the Act by causing them to believe that they could not leave the ministry or that they would face serious harm in doing so. The district court granted summary judgment for Defendants, concluding (1) Marc's allegations of instances of physical force against him did not raise a triable issue of material fact on his forced-labor claim; and (2) Marc's and Claire's claims of psychologically coerced labor were barred by the ministerial exception. The Ninth Circuit Court of Appeals affirmed, holding (1) the Headleys did not establish a genuine issue of fact regarding whether they were victims of forced-labor violations; and (2) the record did not allow the conclusion that the Church or Center violated the Act. View "Headley v. Church of Scientology Int'l" on Justia Law

Defendant pled guilty to mail fraud and money laundering. Based on the sentencing factors set out in 18 U.S.C. 3553(a), the district court imposed a prison sentence longer than the one proposed by the parties in the plea agreement and also in excess of the range recommended by the advisory Sentencing Guidelines. Defendant appealed his sentence, claiming both procedural error and substantive unreasonableness. The Ninth Circuit Court of Appeals affirmed, holding (1) though it imposed a sentence outside of the Guidelines range, the district court did not err by failing to provide prior notice under Fed. R. Crim P. 32(h), as this notice was not required when varying a sentence based on section 3553(a) factors; and (2) the district court did not impermissibly rely on Defendant's inability to pay restitution by considering the financial impact his crimes had on his victims. View "United States v. Rangel" on Justia Law

Defendant was convicted by a jury of drug-related crimes involving the distribution of methamphetmaine, cocaine, and marijuana. Defendant appealed the district court's denial of his motion to suppress evidence obtained from a series of electronic surveillance orders authorizing interception of communications over cellular phones associated with him and his alleged co-conspirators. Defendant contended that these orders by their terms authorized more than standard intercepts, permitting more intrusive roving intercepts without meeting the statutory prerequisites of 18 U.S.C. 2518. The Ninth Circuit Court of Appeals affirmed, holding (1) if the government seeks authorization for the use of new technology to convert cellular phones into roving bugs, it must specifically request that authority, the court must scrutinize the need for such surveillance, and the authorization orders must be clear and unambiguous; but (2) in this case, the district court did not err in finding that the orders were intended only to authorize standard interception techniques and that the government did not do otherwise. View "United States v. Oliva" on Justia Law

M.P., a student with disabilities, appealed the district court's ruling that the Anchorage School District (ASD) did not deny him a free and appropriate public education (FAPE) because the failure to develop an updated Individualized Education Program (IEP) was mostly attributable to his "parents' litigious approach." The Individuals with Disabilities Education Act (IDEA) mandates that public educational agencies review and revise annually an eligible child's IEP. The Ninth Circuit Court of Appeals reversed in part, holding (1) the district court relied on an improper basis when it declined to consider whether the ASD complied with the IDEA's substantive requirements; (2) the ASD deprived M.P. of a substantively adequate FAPE by relying on an outdated IEP to measure M.P.'s academic and functional performance and provide educational benefits to M.P.; and (3) M.P.'s parents were entitled to reimbursement for private tutoring expenses incurred in 2008 and review of the propriety of private tutoring expenses incurred in 2009. Remanded. View "Anchorage Sch. Dist. v. M.P." on Justia Law

Sean Runningeagle and his cousin Corey Tilden were convicted of murdering two victims. The state trial court imposed a sentence of death upon Runningeagle but not upon Tilden. Runningeagle's direct and collateral appeals were rejected by the state courts. Runningeagle subsequently appealed the district court's denial of his federal petition for a writ of habeas corpus and request for an evidentiary hearing. The Ninth Circuit affirmed, holding (1) the state courts' denial of Runningeagle's claim that prosecutors withheld evidence obtained from a former cell-mate of Tilden's in violation of Brady v. Maryland was not an unreasonable application of or contrary to clearly established law; (2) the state Supreme Court's holding that counsel did not provide ineffective assistance was not an unreasonable application of the standard established in Strickland v. Washington; and (3) the state Supreme Court's determination that certain comments made by the prosecutor, while improper, did not amount to a due process violation was not an unreasonable application of clearly established federal law. View "Runningeagle v. Schriro" on Justia Law

In 1993, James Alderson filed a qui tam action under the False Claims Act (FCA) alleging Medicare fraud by Quorum Health Group, Inc., a hospital management company, and several related entities including the Hospital Corporation of America, Inc. (HCA). The United States intervened in 1998. The United States settled its FCA claims against HCA for $631 million in 2003. Alderson received sixteen percent of the settlement as his relator's share. Alderson and related taxpayers, Appellants, filed income tax returns for tax year 2003 reporting the relator's share as ordinary income. They later filed amended returns characterizing it as capital gain, seeking refunds of about $5 million. The Internal Revenue Service (IRS) denied the refund claims. Appellants then filed suit in federal district court. The court granted summary judgment to the United States, holding that the relator's share was ordinary income. The Ninth Circuit Court of Appeals affirmed, holding that Alderson's qui tam award under the FCA was ordinary income. View "Alderson v. United States" on Justia Law