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

The plaintiff, Purushothaman Rajaram, a naturalized U.S. citizen, alleged that Meta Platforms, Inc., refused to hire him because it preferred to hire noncitizens holding H1B visas, to whom it could pay lower wages. Rajaram claimed that this constituted employment discrimination under 42 U.S.C. § 1981, which prohibits discrimination in hiring against U.S. citizens based on their citizenship.The district court dismissed Rajaram's complaint, ruling that section 1981 does not prohibit discrimination based on U.S. citizenship. Rajaram appealed this decision to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit disagreed with the district court's interpretation of section 1981. The appellate court held that the statutory text of section 1981 prohibits employers from discriminating against U.S. citizens. The court reasoned that an employer that discriminates against U.S. citizens gives one class of people—noncitizens—a greater right to make contracts than U.S. citizens. This interpretation, the court held, is consistent with the plain language of the statute, which guarantees that all persons shall have the same right to make and enforce contracts as is enjoyed by white citizens.The Ninth Circuit reversed the district court's dismissal of Rajaram's employment discrimination action and remanded the case for further proceedings. The court concluded that section 1981 does prohibit discrimination in hiring against U.S. citizens on the basis of their citizenship. View "RAJARAM V. META PLATFORMS, INC." on Justia Law

The case involves Jeremy and Kristy Morris, who sued the West Hayden Estates First Addition Homeowners Association (HOA) under the Fair Housing Act. The Morrises alleged that the HOA discriminated against them based on religion by attempting to prevent them from conducting a Christmas program. The jury ruled in favor of the Morrises, awarding them compensatory and punitive damages. However, the district court granted judgment as a matter of law to the HOA, alternatively granted a new trial, and issued a permanent injunction against future productions of the Christmas program that violate the HOA’s covenants, conditions, restrictions, and easements.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s judgment. The appellate court held that the district court properly granted judgment as a matter of law to the HOA as to the Morrises’ disparate treatment claim under 42 U.S.C. § 3604(b) because they did not show that they were adversely affected by the HOA’s actions. However, the court reversed the district court's judgment as a matter of law on the Morrises’ claim that the HOA interfered with their right to purchase and enjoy their home free from discrimination, in violation of 42 U.S.C. § 3617. The court affirmed the district court’s grant of a new trial to the HOA as to the § 3617 claim and vacated the district court’s grant of an injunction to the HOA. The case was remanded for further proceedings. View "MORRIS V. WEST HAYDEN ESTATES FIRST ADDITION HOMEOWNERS ASSOCIATION, INC." on Justia Law

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

In March 2020, Idaho enacted the Fairness in Women’s Sports Act, a law that categorically bans transgender women and girls from participating in women's student athletics. The Act also provides a sex dispute verification process, which allows any individual to dispute the sex of any student athlete participating in female athletics in the State of Idaho and require her to undergo intrusive medical procedures to verify her sex. Lindsay Hecox, a transgender woman who wished to try out for the Boise State University women’s track and cross-country teams, and Jane Doe, a cisgender woman who played on high school varsity teams and feared that her sex would be disputed under the Act due to her masculine presentation, filed a lawsuit against the Act.The United States District Court for the District of Idaho granted a preliminary injunction against the Act, holding that it likely violated the Equal Protection Clause of the Fourteenth Amendment. The court found that the Act subjects only students who wish to participate in female athletic competitions to an intrusive sex verification process and categorically bans transgender girls and women at all levels from competing on female teams. The court also found that the State of Idaho failed to provide any evidence demonstrating that the Act is substantially related to its asserted interests in sex equality and opportunity for women athletes.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision, holding that the Act likely violates the Equal Protection Clause. The court found that the Act discriminates on the basis of transgender status and sex, and that it is not substantially related to its stated goals of equal participation and opportunities for women athletes. The court remanded the case to the district court to reconsider the appropriate scope of injunctive relief. View "Hecox v. Little" on Justia Law

The case involves Rosalina Calonge, who sued Officer Edward Carboni and the City of San Jose under 42 U.S.C. § 1983, alleging that Officer Carboni used excessive deadly force when he shot and killed her son, Francis Calonge. The incident occurred when police officers responded to 911 calls reporting a man with a gun. They located Francis Calonge, who had what appeared to be a gun in his waistband. Officer Carboni shot and killed Calonge after following him for about a minute as he walked down a street.The United States District Court for the Northern District of California granted summary judgment in favor of Officer Carboni, ruling that he was entitled to qualified immunity because the plaintiff had failed to identify specific caselaw clearly establishing that Officer Carboni’s conduct violated the Fourth Amendment.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court found that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could decide that Officer Carboni violated Calonge’s Fourth Amendment right to be free from excessive force. The court also concluded that the relevant law was clearly established at the time, so Officer Carboni was not entitled to qualified immunity. The court resolved three disputed facts in the plaintiff’s favor for purposes of the appeal: Calonge was not drawing his gun or making a threatening gesture when Officer Carboni shot him; there were no bystanders in Calonge’s vicinity when he was shot; and officers did not instruct Calonge to get on the ground or otherwise stop. The court held that the totality of the circumstances did not justify deadly force. View "CALONGE V. CITY OF SAN JOSE" on Justia Law

Seattle Pacific University (SPU), a religious institution, filed a lawsuit against the Washington Attorney General, alleging First Amendment violations arising from the Attorney General's investigation into the university's employment policies and history under the Washington Law Against Discrimination (WLAD). SPU prohibits employees from engaging in same-sex intercourse and marriage. After receiving complaints, the Attorney General requested documents related to SPU's employment policies, employee complaints, and job descriptions. SPU sought to enjoin the investigation and any future enforcement of WLAD.The district court dismissed the suit, citing lack of redressability and Younger abstention. The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that SPU failed to allege a cognizable injury for its retrospective claims, as the Attorney General's request for documents carried no penalties for non-compliance. However, the court found that SPU had standing for its prospective pre-enforcement injury claims, as SPU intended to continue employment practices arguably proscribed by WLAD, the Attorney General had not disavowed its intent to investigate and enforce WLAD against SPU, and SPU's injury was redressable. The court also held that Younger abstention was not warranted as there were no ongoing enforcement actions or any court judgment. The case was remanded to the district court to consider prudential ripeness. View "SEATTLE PACIFIC UNIVERSITY V. FERGUSON" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law

The case revolves around Elizabeth Carley, an inmate in the custody of the Nevada Department of Corrections (NDOC), who filed a suit against Dr. Romeo Aranas, the former Medical Director of NDOC. Carley alleged that Dr. Aranas was deliberately indifferent to her medical needs when he denied her request for certain Hepatitis C (HCV) treatment. The district court denied Dr. Aranas' motion for summary judgment, concluding that he was not entitled to qualified immunity at that time.Previously, the district court had concluded that there was a genuine dispute of material fact as to whether Dr. Aranas was deliberately indifferent to Carley's serious medical needs. However, it did not proceed to the second step of the qualified immunity inquiry, which was whether the violation was clearly established at the time of the violation.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Dr. Aranas was entitled to qualified immunity because no clearly established law rendered the HCV policies unconstitutional at the time of the alleged violation. The court concluded that no decision of the Supreme Court, this court, or a “consensus of courts” would have put Dr. Aranas on notice that the relevant inmate treatment prioritization schemes violated the Eighth Amendment during his time as the NDOC Medical Director. Therefore, the court reversed the district court’s order and remanded with instructions to grant summary judgment for Dr. Aranas. View "CARLEY V. ARANAS" on Justia Law

A class of indigent criminal defendants in Oregon, who were incarcerated and awaiting trial without legal representation, filed a federal habeas corpus petition. They argued that the state's failure to provide them with counsel violated their Sixth Amendment rights. The district court issued a preliminary injunction requiring that counsel be provided within seven days of the initial appearance, and if this did not occur, the defendants must be released from custody subject to reasonable conditions imposed by Oregon Circuit Court judges.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the district court did not abuse its discretion in concluding that the petitioners were likely to succeed on the merits of their Sixth Amendment claim. The court reasoned that without counsel, the petitioners could not understand, prepare for, or progress to critical stages of their cases. The court also held that the district court did not abuse its discretion in concluding that the petitioners were suffering and would continue to suffer irreparable harm. The court found that the public has an interest in a functioning criminal justice system and the protection of fundamental rights. View "Betschart v. Washington County Circuit Court Judges" on Justia Law

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