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

Articles Posted in Constitutional Law
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The Clinics filed suit challenging California Welfare and Institutions Code 14131.10, which eliminated certain Medi-Cal benefits that the state deemed optional, including adult dental, podiatry, optometry, and chiropractic services. The court reversed the district court's holding that the Clinics have a private right of action to challenge the Department's implementation of the state plan amendments (SPA) prior to obtaining approval; affirmed that the Clinics have a private right of action to bring a claim pursuant to 42 U.S.C. 1983 challenging the validity of section 14131.10; and reversed the district court's interpretation of the Medicaid Act, 42 U.S.C. 1396 et seq., holding that section 14131.10 impermissibly eliminated mandatory services from coverage. View "California Ass'n of Rural Health Clinics v. Douglas" on Justia Law

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Plaintiffs challenged the constitutionality of certain sections of California Senate Bill 6 (SB 6). SB 6, implementing California's Proposition 14 (Prop. 14), fundamentally changes the California election system by eliminating party primaries and general elections with party-nominated candidates, and substituting a nonpartisan primary and a two-candidate runoff. The court concluded that it had jurisdiction over the appeal; Plaintiff Chamness' case was not moot where his claim was capable of repetition because future election administrators would deny him the ability to use the designation "Independent" on the primary ballot; Plaintiffs Frederick's and Wilson's appeal were moot because they only sought declaratory relief affecting future elections; and Intervenor Galacki's claims regarding his write-in candidacy and the vote he cast for himself in the general election were moot. In Case No. 11-56449, the court held that Chamness failed to establish that SB 6 severely burdened his rights, and upheld the constitutionality of the statute as reasonably related to furthering the state's important interest in efficiently regulating elections. In Case No. 56303, the court held that the trial court acted well within its discretion in concluding that allowing Galacki to intervene would entail substantial delays and inefficiencies resolving the case, and in therefore denying Galacki's motion as untimely. Accordingly, the court affirmed the trial court's order granting defendants summary judgment and denying Galacki's motion to intervene. View "Chamness v. Maldonado" on Justia Law

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Plaintiff sued defendant and the Church in Japan, alleging that they had tortiously induced her to transfer nearly all of her assets to the Church. After the Japanese courts awarded plaintiff a tort judgment, the Church contended that the judgment imposed liability for its religious teachings in violation of its constitutional right to free exercise of religion. The court affirmed the district court's judgment in favor of plaintiff, holding that the district court's recognition and enforcement of the judgment did not constitute "state action" triggering direct constitutional scrutiny. The court also held that neither the Japanese judgment nor the cause of action on which it was based rose to the level of repugnance to the public policy of California or of the United States that would justify a refusal to enforce the judgment under California's Uniform Foreign-Country Money Judgments Recognition Act, Cal. Civ. Proc. Code 1713-1724. View "Ohno v. Yasuma" on Justia Law

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Plaintiff sued police officers for their alleged use of excessive force in violation of plaintiff's Fourth Amendment rights. Plaintiff was awarded compensatory damages after a jury found that the officers' use of force was constitutionally excessive. Both parties cross-appealed. The court affirmed the district court's entry of judgment on the jury's verdict because the officers were not entitled to qualified immunity. The court held, however that the district court abused its discretion by failing to adequately explain its decision to reduce the amount awarded to plaintiff and in denying plaintiff pre-and post-judgment interest. Accordingly, the court reversed those portions of the district court's orders, remanding for further proceedings. View "Barnard v. Theobald" on Justia Law

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This case stemmed from disputes over the estate of the late Texas oil magnate and billionaire J. Howard Marshall. J. Howard died in 1995, leaving nearly all his assets to his son, Pierce, but excluding his wife, Anna Nicole Smith (Vickie), and his other son, Howard, from receiving any part of his fortune. Howard and his Wife eventually filed for Chapter 11 bankruptcy and their case was assigned to Judge Bufford, who had previously presided over Vickie's Chapter 11 bankruptcy case. Judge Bufford published three separate opinions: (1) denying Pierce's motion for reassignment or recusal; (2) confirming the Plan and denying Pierce's motion to dismiss with respect to his constitutional arguments; and (3) confirming the Plan and denying Pierce's motion to dismiss with respect to his statutory arguments. Elaine, Pierce's widow, now appeals the district court's decision, contending that the district court erred in affirming the bankruptcy court's orders. The court addressed the various issues on appeal related to the motion for recusal or reassignment, constitutional issues, and non-constitutional issues, and ultimately affirmed the district court's decision. View "In the Matter of: Marshall" on Justia Law

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Defendant moved to dismiss his federal grand jury indictment, charging him with one count of possessing child pornography, on double jeopardy grounds because he had been subject to nonjudicial proceedings (NJP) with the Coast Guard. At issue was whether the Double Jeopardy Clause prohibited civilian criminal prosecution of a servicemember who previously received NJP without being informed of or waiving his statutory right to reject such punishment and demand a court-martial instead. The court concluded that the inquiry for the Double Jeopardy Clause was whether the defendant actually was previously placed in jeopardy, not whether he might have been placed in jeopardy if other procedures had been followed. Therefore, the court held that defendant's prosecution did not violate the Double Jeopardy Clause. The court also rejected defendant's alternative argument, reversing and remanding for further proceedings. View "United States v. Stoltz" on Justia Law

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This case arose when plaintiff filed a state-law wage-and-hour class action naming CHA as a defendant. On appeal, defendants challenged the district court's remand to state court under the Class Action Fairness Act (CAFA), 28 U.S.C. 153(c)(1). At issue was whether the two thirty-day periods described in 28 U.S.C. 1446(b)(1) and (b)(3) were the only periods during which the defendant could remove, or if they were merely periods during which a defendant must remove if one of the thirty-day time limits was triggered. The court concluded that sections 1441 and 1446, read together, permitted a defendant to remove outside the thirty-day periods on the basis of its own information, provided that it had not run afoul of either of the thirty-day deadlines. Accordingly, the court held that removal was not barred in this case and remanded to the district court for further proceedings. View "Roth, et al. v. CHA Hollywood Medical Center, et al." on Justia Law

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The Bank filed a motion for relief from an automatic stay and submitted a copy of the promissory note, which was a second-generation copy, as well as a declaration certifying that the original note was in the Bank's files. The trustee argued that a duplicate of a duplicate of the original was insufficient to establish prudential standing. The court concluded that a duplicate of a duplicate was a duplicate for purposes of Federal Rule of Evidence 1003 and concluded that the Bank established prudential standing to file the motion for relief from the stay. View "In re: Toni Griffin" on Justia Law

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The Committee filed suit seeking a declaration that certain portions of a Montana statute making it a criminal offense for any political party to "endorse, contribute to, or make an expenditure to support or oppose a judicial candidate" in a nonpartisan judicial election, Mont. Code Ann. 13-35-231, were unconstitutional and requesting an injunction against its enforcement. The court concluded that, to the extent appellants challenged the permanent injunction against enforcement of section 13-35-231's ban on endorsements and expenditures, the court was bound to follow its published decision finding those provisions unconstitutional. Accordingly, the court affirmed the district court's entry of a permanent injunction as it pertains to those portions of the statute. However, the district court mistakenly entered a permanent injunction against the enforcement of section 13-35-231 in its entirety. Accordingly, the court remanded to the district court with instructions to revise the permanent injunction so that it enjoined only the statute's ban on endorsements and expenditures, and not the statute's ban on contributions. View "Sanders Cnty. Republican Cent. Comm. v. Fox, et al." on Justia Law

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Plaintiffs filed a class action challenging the constitutionality of Arizona's Proposition 100. Proposition 100 commands that Arizona state courts could not set bail for serious felony offenses as prescribed by the legislature if the person charged has entered or remained in the United States illegally and if the proof was evident or the presumption great as to the charge. After reviewing the record, the court affirmed the district court's grant of summary judgment and partial dismissal, concluding that plaintiffs have not raised triable issues of fact as to whether Proposition 100 and its implementing procedures violated the substantive and procedural due process guarantees of the United State's Constitution's Fourteenth Amendment, the Excessive Bail Clause of the Eighth Amendment, and the Sixth Amendment right to counsel, nor whether the Proposition 100 laws were preempted by federal immigration law. The court concluded that the Arizona Legislature and Arizona voters passed the Proposition 100 laws to further the state's legitimate and compelling interest in seeing that those accused of serious state-law crimes were brought to trial. View "Lopez-Valenzuela v. County of Maricopa" on Justia Law