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

Plaintiffs filed suit under 42 U.S.C. 1983 and state civil rights law, contending that the impoundment of their vehicles by local authorities based on plaintiffs' lack of a driver's license violated the Fourth Amendment. California Vehicle Code 4602.6(a)(1) provides that a peace officer may impound a vehicle for 30 days if the vehicle’s driver has never been issued a driver's license.Applying Brewster v. Beck, 859 F.3d 1194, 1196–97 (9th Cir. 2017), the panel held that 30-day impounds under section 14602.6 are seizures for Fourth Amendment purposes. Therefore, the only issue in this case was whether the impounds were reasonable under the Fourth Amendment. The panel held that, although the state's interest in keeping unlicensed drivers off the road is governed by the community caretaking exception of the Fourth Amendment, the exception does not categorically permit government officials to impound private property simply because state law does. Furthermore, even if the panel were to balance the state's interest against the driver's interests, the County would still be wrong to rely on a deterrence or administrative penalty rationale to support California's interests. Therefore, the panel affirmed the district court's grant of summary judgment for plaintiffs on the Fourth Amendment claims.The panel affirmed the district court's grant of summary judgment on plaintiffs claim that the County and the City were liable for money damages as final policymakers who caused the constitutional violations; affirmed the denial of class certification for lack of commonality and typicality; and affirmed summary judgment for defendants on the California Bane Act claim. View "Sandoval v. County of Sonoma" on Justia Law

Inmates at the ADC, and the Arizona Center for Disability Law, filed suit against senior ADC officials, alleging that ADC's policies and practices governing health care delivery in ADC prisons and conditions of confinement in ADC isolation units exposed them to a substantial risk of serious harm to which defendants were deliberately indifferent. The parties eventually entered into a settlement agreement in which defendants agreed to comply with more than 100 performance measures. At issue on appeal were the district court's rulings interpreting and enforcing the settlement agreement.Determining that it had jurisdiction, the Ninth Circuit affirmed the district court's November 10, 2016 Outside Provider Order; reversed the February 3, 2017 ruling that the Stipulation precludes it from issuing a general staffing order; and reversed the December 23, 2016 ruling that close custody inmates are part of the subclass. The panel noted that the district court may, in the future, consider ordering defendants to develop and implement a plan to increase staffing in general as a remedy for defendants' non-compliance. Furthermore, offering close custody inmates 15.5 hours or more out-of-cell time per week is sufficient to place these inmates outside of the subclass for purposes of monitoring compliance with the Stipulation. View "Parsons v. Ryan" on Justia Law

Plaintiff filed suit under the Administrative Procedure Act (APA) against St. James after she was terminated from her teaching position when she told the school that she had breast cancer and would need to miss work to undergo chemotherapy. The Ninth Circuit reversed the district court's grant of summary judgment for the school, holding that, based on the totality of the circumstances test under Hosanna-Tabor Evangelical Lutheran Church & School v. E.E.O.C., 565 U.S. 171 (2012), the First Amendment's ministerial exception did not foreclose plaintiff's claim. In this case, plaintiff did not have any credentials, training, or ministerial background; there was no religious component to her liberal studies degree or teaching credential; St. James had no religious requirements for her position; and St. James did not hold plaintiff out as a minister. View "Biel v. St. James School" on Justia Law

After federal agencies issued two interim final rules (IFRs) exempting employers with religious and moral objections from the Affordable Care Act requirement that group health plans cover contraceptive care without cost sharing, states filed suit to enjoin the enforcement of the IFRs. The Ninth Circuit affirmed that venue was proper in the Northern District of California; affirmed that plaintiff states have standing to sue based on procedural injury where the states have shown with reasonable probability that the IFRs will first lead to women losing employer-sponsored contraceptive coverage, which will then result in economic harm to the states; affirmed the preliminary injunction insofar as it barred enforcement of the IFRs in the plaintiff states; but vacated the portion of the injunction barring enforcement in other states because the scope of the injunction was overbroad. View "California v. Azar" on Justia Law

Plaintiff, a candidate for public office in California, challenged the California Elections Code, which mandated that the primary ballot list his party preference as "None" instead of the Socialist Party USA.The Ninth Circuit reversed and remanded, holding that California, at this very early stage of the litigation, failed to demonstrate as a matter of law why its ballot must describe plaintiff as having no party preference when in fact he preferred the Socialist Party USA. The panel agreed with the Secretary of State that the burden the California statutes imposed on plaintiff's First and Fourteenth Amendment rights was not severe. However, the burden imposed on plaintiff's rights was more than "slight" and warranted scrutiny that was neither strict nor wholly deferential. In this case, the primary purported justification for the statutes—avoiding voter confusion—was an important government interest, but it was unclear why less burdensome and less misleading alternatives would not accomplish the state's goals. View "Soltysik v. Padilla" on Justia Law

A 2006 Initiative, amending Alaska’s election laws, returned the individual-to-candidate and individual-to-group limits to their pre-2003 levels of $500 per year, Alaska Stat. 15.13.070(b)(1); capped the amount a non-political party group could contribute to a candidate at $1,000; restricted the amount candidates could receive from nonresidents to $3,000 per year, and limited the amount a political party, including its subdivisions, could contribute to a candidate. The voter information packet included a statement that "Corruption is not limited to one party or individual. Ethics should be not only bipartisan but also universal. From the Abramoff and Jefferson scandals in Washington D.C. to side deals in Juneau, special interests are becoming bolder every day. They used to try to buy elections. Now they are trying to buy the legislators themselves." In 2015, Plaintiffs brought a First Amendment challenge. The Ninth Circuit held that affirmance on the individual-to-candidate and individual-to-group limits was compelled by precedent and upheld the political party-to-candidate limit. Those restrictions were narrowly tailored to prevent quid pro quo corruption or its appearance and did not impermissibly infringe constitutional rights. The court held that the nonresident limit, which at most, targeted contributors’ influence over Alaska politics, did not target an “important state interest” and therefore violated the First Amendment. View "Thompson v. Hebdon" on Justia Law

Plaintiffs filed suit against Officer Jeremy Hellawell under 42 U.S.C. 1983, after the officer fatally shot and killed Ernest Foster. The district court denied the officer's motion for summary judgment based on qualified immunity.The Ninth Circuit held that it lacked jurisdiction to consider questions of evidentiary sufficiency on interlocutory review, and thus dismissed the officer's appeal of the district court's order with respect to the claims that the shooting violated Foster's Fourth Amendment right and plaintiffs' Fourteenth Amendment rights. The panel reversed the district court's denial of qualified immunity on the Fourth Amendment claims, holding that the officer's actions during the investigative stop did not violate any clearly established law. In this case, the officer had reasonable suspicion to stop and investigate Foster after the 911 call warning of an armed man matching Foster's description, and unholstering a gun during the stop did not constitute a violation of Foster's right to be free from excessive force. View "Foster v. Hellawell" on Justia Law

A plaintiff need not plead that racism was the but-for cause of a defendant's conduct, but only that racism was a factor in the decision not to contract such that the plaintiff was denied the same right as a white citizen. Mixed-motive claims are cognizable under 42 U.S.C. 1981.Entertainment Studios, along with NAAAOM, filed suit alleging that Charter's refusal to enter into a carriage contract was racially motivated and in violation of section 1981. The Ninth Circuit affirmed the district court's denial of Charter's motion to dismiss, holding that the complaint sufficiently alleged that discriminatory intent played at least some role in Charter's refusal to contract with Entertainment Studios and thus denied Entertainment Studios the same right to contract as a white-owned company. The panel also held that plaintiffs' 1981 claim was not barred by the First Amendment where section 1981 was a content-neutral regulation that would satisfy intermediate scrutiny. The panel noted that the fact that cable operators engage in expressive conduct when they select which networks to carry did not automatically require the application of strict scrutiny in this case. View "National Association of African American-Owned Media v. Charter Communications, Inc." on Justia Law

Plaintiffs have failed to raise a genuine issue of material fact on whether racial considerations predominated the City of Los Angeles's redistricting process. The Ninth Circuit affirmed the district court's protective order and its order granting summary judgment for the City in an action alleging that race was the predominant motivator in drawing the boundaries of council districts in the Council District 10 redistricting ordinance.Viewed in the light most favorable to plaintiffs, the panel held that the record failed to show that successive boundary amendments were driven predominantly by racial considerations. Rather, the Commission sought to rebalance the populations in each Council District, while preserving communities and unifying as many Neighborhood Councils as possible in a single Council District. The panel also held that the legislative privilege protected local officials from being deposed. View "Lee v. City of Los Angeles" on Justia Law

Petitioner appealed the district court's denial of his first federal petition for a writ of habeas corpus. The Ninth Circuit affirmed in part, reversed in part, and remanded for an evidentiary hearing on one of petitioner's penalty-phase ineffective assistance of counsel claims.The panel held that petitioner was entitled to equitable tolling for the period from August 29, 1998, to September 17, 1999, and thus reversed the district court's contrary ruling. The panel remanded for further proceedings as to Claims 1(C), 1(D), 1(E), 1(H), 1(I), 1(J), 9, and 14. In regard to two related claims alleging ineffective assistance of trial counsel, the panel held that the district court did not abuse its discretion in denying an evidentiary hearing as to Claim 1(A). However, the district court abused its discretion in denying an evidentiary hearing as to Claim (F). Therefore, the panel remanded for the district court to hold an evidentiary hearing so that it may properly assess whether the evidence of petitioner's childhood abuse and trauma -- in combination with the brain damage evidence that was not on its own sufficient -- gave rise to a reasonable probability that the outcome of petitioner's sentencing hearing would have been different. Finally, the panel affirmed the district court's denial of petitioner's motion for relief under Federal Rule of Civil Procedure 60(b). View "Williams v. Filson" on Justia Law