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

Arizona filed suit against ASARCO on behalf of Angela Aguilar and the state. Aguilar later filed her own suit, alleging sexual harassment, retaliation, and constructive discharge. These proceedings were consolidated and removed to federal court. The jury found ASARCO liable on the sexual harassment claims only and the jury did not find any compensatory damages for Aguilar, instead awarding her one dollar in nominal damages for the sexual harassment claim. The jury also awarded Aguilar $868,750 in punitive damages. The district court subsequently ordered that the punitive damages be reduced to $300,000, which was the statutory maximum under Title VII for an employer of ASARCO's size. The court concluded that the punitive damages award was outside of constitutional limits and must be vacated. The court concluded that the requirement of a reasonable relationship between compensatory and punitive damages suggested that these damages should be reduced. However, given ASARCO's highly reprehensible conduct and the presence of a comparable civil penalty in the form of the Title VII damages cap, the court concluded that the Constitution did not bar the imposition of a substantial punitive award. Therefore, on remand, the district court could reorder a new trial unless plaintiff accepted a remittitur of $125,000. View "State of Arizona v. ASARCO" on Justia Law

Plaintiffs filed suit under the Clean Air Act (CAA), 42 U.S.C. 7401-7671q, seeking to compel the Agencies to regulate greenhouse gas emissions from the state's five oil refineries under the CAA. On appeal, Intervenor WSPA argued that plaintiffs lacked Article III standing. The court concluded that the district court lacked jurisdiction to hear the parties' dispositive motions on the merits because plaintiffs have not met their burden in satisfying the "irreducible constitutional minimum" requirements for Article III standing under either the causality or redressability prong discussed in Lujan v. Defenders of Wildlife. Accordingly, the court vacated the district court's order on the parties' dispositive motions and remanded with instructions that the action be dismissed for lack of subject matter jurisdiction. View "Wash. Envtl. Council v. Bellon" on Justia Law

Arizona’s 2010 Senate Bill 1070 includes various immigration-related provisions, passed in response to the growing presence of unauthorized aliens in Arizona. The stated purpose of S.B. 1070 is “to make attrition through enforcement the public policy of all state and government agencies in Arizona” by creating “a variety of immigration-related state offenses and defin[ing] the immigration-enforcement authority of Arizona’s state and local law enforcement officers.” Section 13-2929 of the Bill attempts to criminalize transporting, concealing, harboring, or attempting to transport, conceal, or harbor an unauthorized alien under certain circumstances and to criminalize inducing or encouraging an unauthorized alien to come to or reside in Arizona. The district court entered a preliminary injunction with respect to 13-2929 on the basis that it is preempted by federal law. The Ninth Circuit affirmed, holding that the statute, as written, is void for vagueness under the Due Process Clause because one of its key elements—being “in violation of a criminal offense”—is unintelligible. The provision is also preempted by federal law and invalid under the Supremacy Clause. View "Valle del Sol, Inc. v. State of Arizona" on Justia Law

Plaintiffs, disabled state prisoners and parolees, filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Rehabilitation Act, 29 U.S.C. 701 et seq., seeking disability accommodations. In these consolidated appeals, defendant challenged the scope of the district court's injunction in light of the amendments to California Penal Code 3056. The court concluded that the August 28 orders, which required California state officials to disseminate and implement a previously negotiated County Jail Plan for disabled persons and parolees, neither conflicted with section 3056 nor required more of defendants than was appropriate to assist in remedying the ADA and Rehabilitation Act violations for which they bear responsibility. Therefore, the court affirmed the remedial August 28 orders issued by the district court. Case No. 12-6018 was dismissed as moot and the court affirmed the district court's order in Case No. 12-17198. View "Armstrong v. Brown" on Justia Law

Plaintiff filed suit against defendants seeking damages for his detention and treatment at Guantanamo Bay. At issue was whether the district court had jurisdiction over the subject matter of this action, given the jurisdiction-stripping provisions in 28 U.S.C. 2241(e). Looking to the plain language of section 2241(e)(2), it was clear that this provision applied to plaintiff's claims, and that, as a result, no court, justice, or judge had authority to hear his action. The court concluded that Boumediene v. Bush did not address section 2241(e)(2), let alone strike it down; because section 2241(e)(2) was capable of functioning independently, and was consistent with Congress's basic objectives in enacting the Military Commissions Act of 2006, Pub. L. No. 109-366, 120 Stat. 2600, the court concluded that it was severable from section 2241(e)(1), and remained in effect, provided that it was constitutional; and section 2241(e)(2) was not unconstitutional as applied to him. Accordingly, the court vacated the district court's order dismissing plaintiff's claims and remanded. View "Hamad v. Gates, et al." on Justia Law

Loops, designer of a flexible toothbrush made for safe use in prisons, bid on a contract with the NYC-DOC. Amercare ultimately won the contract using a similar toothbrush. Amercare filed a defamation suit against Loops after Loops alleged that Amercare had engaged in procurement fraud. The court concluded that the district court did not abuse its discretion by entertaining Washington's anti-SLAPP motion, Wash. Rev. Code 4.25.510; under section 4.25.510, Loops was immune for all statements made to government agencies; the statute of limitations barred claims regarding the product alteration and counterfeiting accusations; and Americare did not show a likelihood of satisfying the elements of defamation. Accordingly, the court affirmed the judgment of the district court. View "Phoenix Trading, Inc. v. Loops LLC" on Justia Law

Plaintiff first applied for social security disability insurance (SSI) benefits ten years ago. When the benefits were denied, plaintiff requested a hearing but the SSA ruled that her request was untimely and denied a subsequent application on the ground of res judicata. The SSA never explained why it rejected plaintiff's facially valid excuse for the delay in her hearing request. The district court then dismissed her action for lack of subject matter jurisdiction. The court reversed and remanded, concluding that the ALJ failed to consider whether plaintiff's facially valid reasons constituted good cause excusing the delay, and deprived plaintiff of her due process right to a meaningful opportunity to be heard and to seek reconsideration of an adverse benefits determination. View "Dexter v. Astrue" on Justia Law

Plaintiffs, the crew of an Ecuadorian fishing boat, filed suit against the United States, alleging that the United States harmed plaintiffs and their property when the Coast Guard boarded the boat in search of drugs. The court held that, on the evidence submitted by the parties, reciprocity with Ecuador existed; the discretionary function exception applied generally to plaintiffs' claims because most of the actions by the Coast Guard were discretionary; the government could have violated its non-discretionary policy of paying damages to the owner of the boat; and to the extent that plaintiffs could establish that the United States violated that mandatory obligation, sovereign immunity did not bar this action. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Tobar v. United States" on Justia Law

Plaintiff, a former Arizona state prisoner, filed suit against defendants, alleging that they violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-12134, and the Rehabilitation Act of 1973 (RA), 29 U.S.C. 794, by failing to reasonably accommodate his disability. Plaintiff picked tomatoes for Eurofresh as a part of a convict labor force. The court concluded that plaintiff's claims against Eurofresh were properly dismissed because plaintiff and Eurofresh were not in an employment relationship, and Eurofresh did not receive federal financial assistance. The court concluded, however, that judgment was improperly granted to the State Defendants where they were liable for disability discrimination committed by a contractor. Accordingly, the court affirmed in part, reversed in part, and remanded to the district court to determine in the first instance whether such discrimination occurred. View "Castle v. Eurofresh, Inc." on Justia Law

After the Department denied Memorial's application for a Certificate of Need to perform elective percutaneous coronary interventions (PCIs), Memorial filed suit alleging that the PCI regulations were an unreasonable restraint of trade in violation of the Sherman Act, 15 U.S.C. 1, and unreasonably discriminated against interstate commerce in violation of the dormant Commerce Clause and 42 U.S.C. 1983. The court concluded that the requirements did not violate the dormant Commerce Clause where the minimum procedure requirement did not burden interstate commerce and the minimum procedure requirement protected public safety. Accordingly, the court affirmed the district court's dismissal of all of Memorial's remaining claims. View "Yakima Valley Mem'l Hosp. v. Dep't of Health" on Justia Law