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

The case involves M&T Farms, a California general partnership between two farmers, who purchased crop insurance under the Whole-Farm Revenue Protection Pilot Policy (the “WFRP Policy”) from Producers Agriculture Insurance Company (“ProAg”), an insurer approved and reinsured by the Federal Crop Insurance Corporation (FCIC). M&T Farms and a third farmer sell farm commodities through a storefront, B&T Farms, which owns their business name and goodwill and is also a California general partnership. M&T Farms filed a claim seeking the full policy amount, which ProAg denied. The FCIC concluded that the WFRP Policy does not allow a partner who files taxes on a fractional share of farming activity conducted by a partnership to be eligible for WFRP coverage for the fractional share of that farming activity.The United States District Court for the Northern District of California granted summary judgment in favor of the FCIC. M&T Farms challenged the FCIC’s decision that a partnership “holding the business name and good will of [others] (i.e., marketing and selling the commodities produced)” is engaged in “farming activity” under section 3(a)(4) of the WFRP Policy, and that therefore, any entity reporting a fractional share of the partnership’s activity on its tax returns is ineligible for WFRP Policy coverage.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that the WFRP Policy contained an ambiguity regarding the definition of “farming activity.” The FCIC’s conclusion that a partnership selling its partners’ products and holding their goodwill and business name was engaged in “farming activity” under section 3(a)(4) of the policy had a reasonable basis and was also reasonable as a matter of policy. Because the FCIC’s interpretation of “farming activity” in the WFRP Policy was reasonable, it survived APA arbitrary and capricious review. The court also held that the term “farming activity” in the WFRP policy was genuinely ambiguous, the FCIC’s conclusion had a reasonable basis, and the FCIC’s conclusion was entitled to controlling weight. View "M & T FARMS V. FEDERAL CROP INSURANCE CORPORATION" 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

The case involves Gerardo Farias-Contreras, who pleaded guilty to conspiring to distribute methamphetamine and heroin. As part of the plea agreement, the government agreed to dismiss two other charges and not to recommend a sentence exceeding the low-end of the guideline range. Farias-Contreras argued for a six-level reduction in the base offense level, resulting in a guidelines range of 108–135 months, citing his many physical disabilities. The government, after reducing the base offense level by three levels, calculated a guidelines range of 151–188 months and recommended a 151-month term.The United States District Court for the Eastern District of Washington sentenced Farias-Contreras to 188 months' imprisonment, citing substantially the facts and argument presented by the government. Farias-Contreras appealed, arguing that the government implicitly breached its promise under the plea agreement not to recommend a sentence in excess of the low-end of the sentencing guidelines range when the government implicitly urged the district court to impose a harsher sentence.The United States Court of Appeals for the Ninth Circuit affirmed the sentence. The court found that the government's conduct crossed the line from permissible advocacy to an improper end-run of the plea agreement, thus implicitly breaching its promise not to recommend a sentence in excess of the low-end of the calculated guideline range. However, the court concluded that the error was not plain because the court's precedent does not make sufficiently clear to what extent the government may respond to a defendant’s request for a downward departure without implicitly breaching the plea agreement. The court took the opportunity to clarify its law on the subject. View "USA V. FARIAS-CONTRERAS" on Justia Law

The Natural Resources Defense Council (NRDC) and other environmental groups sued the Bureau of Reclamation and the Fish and Wildlife Service (FWS), alleging that they violated the Administrative Procedure Act (APA) and Endangered Species Act (ESA) by failing to adequately consult over whether the renewal of government water supply contracts would likely jeopardize the existence of the delta smelt and by failing to reinitiate consultation with the National Marine Fisheries Service (NMFS) regarding the contracts’ effects on Chinook salmon. The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision, holding that the federal agencies complied with their obligations under the APA and ESA. The court found that FWS's consultation on the renewal of the contracts was not arbitrary and capricious, and that Reclamation did not act arbitrarily and capriciously by relying on it. The court also rejected NRDC's argument that Reclamation violated its obligations under the ESA by misinforming FWS regarding the scope of its discretion to negotiate the contracts. Finally, the court concluded that the renewed contracts did not give Reclamation the discretion to take measures that would benefit the Chinook salmon, and therefore the district court did not err in dismissing NRDC's fifth claim for relief for failure to state a claim. View "NRDC v. Haaland" 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

The case involves Jacobo Jajati, a U.S. citizen, who had his membership in the Secure Electronic Network for Travelers Rapid Inspection (SENTRI) program revoked by the U.S. Customs and Border Protection (CBP). SENTRI is a program that allows pre-approved, low-risk travelers to cross the U.S.-Mexico border more easily. Jajati's membership was revoked, reinstated, and then revoked again without explanation. Jajati filed a lawsuit claiming that CBP's decision to revoke his SENTRI membership was arbitrary and capricious, in violation of the Administrative Procedure Act (APA).The district court dismissed Jajati's claim, ruling that CBP's decisions to revoke SENTRI memberships were not subject to judicial review because the administration of SENTRI was committed to agency discretion under the APA. The court held that there were no judicially manageable standards to assess how and when CBP should exercise its discretion to revoke SENTRI memberships.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the APA does not bar judicial review of Jajati's claims. The court found that while CBP has broad discretion to revoke SENTRI memberships, the APA recognizes that discretion can be abused. The court concluded that the law governing SENTRI provides meaningful standards under which courts can review whether CBP wielded its discretion in a permissible manner. The case was remanded to the district court to consider whether CBP's decision to revoke Jajati's SENTRI membership violated the APA. View "JAJATI V. UNITED STATES CUSTOMS AND BORDER PROTECTION" on Justia Law

The case involves the United States government's appeal against a district court's order to pay monetary sanctions for failing to disclose information that suggested its key witness in a criminal trial was willing to shape her testimony in exchange for certain benefits. The case arose from a five-body homicide trial where the government's star witness, Esmeralda, was willing to alter her testimony for benefits. The defense learned about this not from the government, but from Esmeralda's counsel. The district court found that the government's failure to disclose this information violated the defendant's due process rights under Brady v. Maryland, and imposed sanctions on the government.The district court's order was appealed by the government before the final judgment was issued in the underlying criminal case. The Ninth Circuit Court of Appeals affirmed the district court's order, holding that it had appellate jurisdiction under 28 U.S.C. § 1291 because the sanctions order satisfied the elements of the collateral-order doctrine.On the merits, the court found that the government had suppressed evidence, and that suppression was material under Brady. The court held that the district court's decision to exclude the testimony and impose sanctions was not an abuse of discretion. The court also held that the district court did not violate the government's sovereign immunity by imposing monetary sanctions under an exercise of its supervisory powers. View "USA V. CLOUD" on Justia Law

A group of environmental organizations challenged the U.S. Forest Service's approval of the Long Valley Exploration Drilling Project, a mineral exploration project on land in the Inyo National Forest in California. The Forest Service had approved the project by invoking two Categorical Exclusions (CEs) under the National Environmental Policy Act (NEPA), which allow certain actions to bypass more extensive environmental review. The environmental groups argued that the Forest Service could not combine two CEs to approve the project when neither CE alone could cover the entire project.The district court granted summary judgment in favor of the Forest Service and KORE Mining Ltd., the company that proposed the project. The environmental groups appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reversed the district court's decision. The court found that the two-phase project was a single proposed action and that the Forest Service's regulations prohibited combining CEs when no single CE could cover a proposed action alone. The court also held that the Forest Service's error in combining the two CEs was not harmless and remanded the case to the district court to enter summary judgment in favor of the environmental groups, vacating the agency's decision. View "FRIENDS OF THE INYO V. USFS" on Justia Law

Diamond S.J. Enterprise, Inc., which operates a nightclub in San Jose, California, had its license suspended for thirty days by the city following a shooting outside the club. The city held an administrative hearing and found that Diamond had operated its venue in a way that caused the shooting and created a public nuisance, violating San Jose's entertainment business licensing provisions. Diamond filed a complaint in federal court, alleging First Amendment and due process violations.The case was first heard in the United States District Court for the Northern District of California, which dismissed Diamond's claims and granted summary judgment for the City of San Jose. The district court ruled that the challenged provisions did not implicate First Amendment rights and that the city had satisfied due process requirements.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's decision, holding that Diamond's facial attack on the city's public entertainment business licensing provisions failed because the provisions did not give city officials unbridled discretion that created a risk of censorship. The court also held that Diamond failed to state a procedural due process claim, as the licensing scheme provided Diamond with notice, an opportunity to be heard, the ability to present and respond to evidence, and a pre-deprivation appeal, followed by post-deprivation review by the California Superior Court. View "Diamond S.J. Enterprise, Inc. v. City of San Jose" on Justia Law

In 2022, the California Legislature directed Pacific Gas & Electric (PG&E) to extend operations at the Diablo Canyon Nuclear Power Plant, despite PG&E's previous plans to cease operations. However, the deadline for a federal license renewal application for continued operation had already passed. PG&E requested an exemption from the U.S. Nuclear Regulatory Commission (NRC) to this deadline, which the NRC granted. The NRC found that the exemption was authorized by law, would not pose an undue risk to public health and safety, and that special circumstances were present. The NRC also concluded that the exemption met the eligibility criteria for a categorical exclusion, meaning no additional environmental review under the National Environmental Policy Act was required.Three non-profit organizations, San Luis Obispo Mothers for Peace, Friends of the Earth, and the Environmental Working Group, petitioned for review of the NRC's decision. The Ninth Circuit Court of Appeals first addressed whether it had jurisdiction to hear a direct appeal from an NRC exemption decision. The court held that it did have jurisdiction, as the substance of the exemption was ancillary or incidental to a licensing proceeding. The court also concluded that the petitioners had Article III standing to bring the case, as they alleged a non-speculative potential harm from age-related safety and environmental risks, demonstrated that Diablo Canyon would likely continue operations beyond its initial 40-year license term, and alleged members’ proximity to the facility.On the merits, the court held that the NRC’s decision to grant the exemption was not arbitrary, capricious, or contrary to law. The court also held that the NRC did not act arbitrarily or capriciously in invoking the National Environmental Policy Act categorical exclusion when issuing the exemption decision. The court concluded that the NRC was not required to provide a hearing or meet other procedural requirements before issuing the exemption decision because the exemption was not a licensing proceeding. The court denied the petition for review. View "SAN LUIS OBISPO MOTHERS FOR PEACE V. UNITED STATES NUCLEAR REGULATORY COMMISSION" on Justia Law