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

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law

Three nonprofit organizations challenged two Arizona election law amendments: one allowing the cancellation of a voter’s registration if they move to another county (the “Cancellation Provision”) and another making it a felony to provide a voting mechanism to someone registered in another state (the “Felony Provision”). The plaintiffs argued these laws would jeopardize voting rights in Arizona.The United States District Court for the District of Arizona preliminarily enjoined the enforcement of both provisions, agreeing with the plaintiffs that the laws could harm voters and were likely unconstitutional. The defendants, including the Arizona Attorney General and the Yuma County Republican Committee, appealed the decision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs lacked Article III standing to challenge the Cancellation Provision because they only alleged a frustrated mission and diverted resources, failing to show direct harm to their core activities. The court emphasized that organizational standing requires more than just a diversion of resources; it requires a direct impact on the organization’s core activities.Regarding the Felony Provision, the court found that the plaintiffs had standing because they faced a realistic possibility of prosecution, which could chill their voter outreach activities. However, the court concluded that the plaintiffs were unlikely to succeed on the merits of their vagueness challenge. The court interpreted the phrase “mechanism for voting” narrowly, determining it referred only to unlawful acts of voting, not voter outreach or registration.The Ninth Circuit vacated the district court’s preliminary injunction and remanded the case for further proceedings consistent with its opinion. View "ARIZONA ALLIANCE FOR RETIRED AMERICANS V. MAYES" on Justia Law

Cenious Brewster led officers on a high-speed chase, which was recorded on the officers’ dashcam. Brewster crashed into a building shortly after the chase began. He was arrested, and a firearm was found in his vehicle. Brewster pleaded guilty to one count of being a felon in possession of a firearm, and the district court sentenced him to 46 months’ imprisonment. Brewster challenged his sentence, arguing that the district court erred in applying the reckless endangerment during flight enhancement under U.S.S.G. § 3C1.2, misunderstood his request for a downward departure based on circumstances that allegedly justified his flight, and violated his due process rights by finding that data from the Sentencing Commission’s Judiciary Sentencing INformation (JSIN) online tool was sufficiently reliable to consider at sentencing.The United States District Court for the Northern District of California denied Brewster’s objections to the reckless endangerment enhancement, finding that his flight created a substantial risk of injury to at least one specific person. The court also rejected Brewster’s request for a downward departure or variance, characterizing it as a request for a variance only, which Brewster’s counsel confirmed. Additionally, the court found the JSIN data reliable and used it to determine Brewster’s sentence, noting that the data was consistent with information from another Sentencing Commission tool, the Interactive Data Analyzer (IDA).The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court held that the district court did not clearly err in finding that Brewster’s flight put at least one motorist at substantial risk of serious bodily injury. The court also found that Brewster forfeited his argument regarding the downward departure and failed to show plain error. Finally, the appellate court held that the district court did not err in finding the JSIN data reliable, as it came from a reliable source and was corroborated by other unchallenged evidence. The court denied Brewster’s motion for supplemental briefing on a Second Amendment challenge, as he could have raised it in the district court but did not. The sentence was affirmed. View "United States v. Brewster" on Justia Law

Kate Adams, the former Chief of Police for the City of Rancho Cordova, was forced to resign over allegations that she sent racist text messages while working for the Sacramento County Sheriff’s Office. The messages, sent in 2013, included offensive images forwarded to two friends during a private conversation. Adams claimed she was merely expressing disapproval of the images. After her resignation, the messages were publicized, leading to further professional and personal repercussions for Adams.The United States District Court for the Eastern District of California dismissed Adams’s First Amendment retaliation and conspiracy claims, ruling that her speech did not address a matter of public concern. The court found that the private nature of the text messages and their content did not relate to broader societal issues or public interest.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that Adams’s private text messages, which were part of a casual conversation and not intended for public dissemination, did not constitute speech on a matter of public concern under the Pickering v. Board of Education standard. The court emphasized that the content, form, and context of the messages indicated they were of personal interest rather than public interest. Consequently, Adams’s First Amendment retaliation and conspiracy claims were dismissed, and the case was remanded for further proceedings on other unresolved claims. View "ADAMS V. COUNTY OF SACRAMENTO" on Justia Law

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

In this case, several plaintiffs challenged Hawaii and California laws that restrict the carrying of firearms in various locations, arguing that these laws violate their Second Amendment rights. The laws in question generally prohibit carrying firearms in places such as parks, beaches, bars, restaurants that serve alcohol, financial institutions, and private property without explicit consent from the property owner.The United States District Court for the District of Hawaii granted a preliminary injunction against Hawaii's law, enjoining the enforcement of the firearm restrictions in parking lots shared by government and non-government buildings, financial institutions, public beaches, public parks, bars, and restaurants that serve alcohol. The court also enjoined the new default rule for private property open to the public. The United States District Court for the Central District of California similarly granted a preliminary injunction against California's law, enjoining the enforcement of firearm restrictions in hospitals, playgrounds, public transit, parks, athletic facilities, places of worship, financial institutions, and private property open to the public.The United States Court of Appeals for the Ninth Circuit reviewed these decisions. The court affirmed the preliminary injunctions in part and reversed them in part. The Ninth Circuit held that some places specified by the Hawaii and California laws likely fall within the national tradition of prohibiting firearms at sensitive places, such as bars and restaurants that serve alcohol, parks, and similar areas. However, the court found that other places, such as financial institutions and places of worship, do not fall within this tradition. The court also held that the new default rule prohibiting the carry of firearms onto private property without consent is likely unconstitutional in California but not in Hawaii.The Ninth Circuit affirmed the preliminary injunctions to the extent that they enjoin restrictions on firearms at financial institutions, parking lots adjacent to financial institutions, and parking lots shared by government and non-government buildings. The court reversed the preliminary injunctions to the extent that they enjoin restrictions on firearms at bars and restaurants that serve alcohol, beaches, parks, and similar areas, and the new default rule prohibiting the carry of firearms onto private property without consent in Hawaii. View "WOLFORD V. LOPEZ" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

Plaintiffs, property developers owning three hotels, alleged that Defendants, rival developers operating the Hollywood Athletic Club, abused the California Environmental Quality Act (CEQA) processes to extort funds in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). Defendants challenged several of Plaintiffs' hotel projects through CEQA objections and lawsuits, which Plaintiffs claimed were baseless and intended to obstruct their developments.The United States District Court for the Central District of California granted summary judgment in favor of Defendants, holding that the Noerr-Pennington doctrine protected Defendants' petitioning activities from statutory liability under the First Amendment. The district court found that Defendants' actions were not objectively baseless and thus did not fall within the sham litigation exception to the Noerr-Pennington doctrine. The case was transferred from Judge Wright to Judge Gutierrez, who reconsidered and reversed the prior denial of summary judgment, concluding that the previous decision was clearly erroneous and would result in manifest injustice.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the district court did not abuse its discretion in reconsidering the prior judge's ruling. It also agreed that Defendants' CEQA challenges were not objectively baseless, as the actions had some merit and were not brought solely for an improper purpose. The court emphasized that the Noerr-Pennington doctrine provides broad protection to petitioning activities to avoid chilling First Amendment rights. Consequently, the court did not need to address Defendants' additional arguments regarding the applicability of RICO to litigation activities. View "RELEVANT GROUP, LLC V. NOURMAND" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law