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

Aquarian Foundation, Inc., a non-profit religious organization, alleged that Bruce Lowndes infringed on its copyrights by uploading spiritual teachings of its late founder, Keith Milton Rhinehart, to various websites. Lowndes claimed he had a license from Rhinehart, granted in 1985, to use the materials. Rhinehart passed away in 1999, bequeathing his estate, including the copyrights, to Aquarian.The United States District Court for the Western District of Washington granted partial summary judgment, confirming that Rhinehart's copyrights were properly transferred to Aquarian via his will. After a bench trial, the court ruled against Aquarian on its claims of copyright infringement, trademark infringement, and false designation of origin. The court found that Rhinehart created the works as his own, not as works for hire, and that he had validly licensed them to Lowndes. The court also determined that Lowndes did not breach the licensing agreement and that Aquarian could not terminate the license under 17 U.S.C. § 203(a). The court denied attorneys’ fees to both parties.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s findings that Rhinehart’s works were not created as works for hire, that he validly licensed the works to Lowndes, and that Lowndes did not breach the licensing agreement. The court also affirmed the decision not to award Lowndes attorneys’ fees under the Lanham Act. However, the Ninth Circuit reversed the district court’s determination regarding the termination of the license, holding that Aquarian’s termination letter in May 2021 was effective. The case was remanded for further proceedings to address any infringement that may have occurred after the license termination, as well as the denial of injunctive relief and attorneys’ fees under the Copyright Act. View "AQUARIAN FOUNDATION, INC. V. LOWNDES" on Justia Law

A nonprofit corporation, Moving Oxnard Forward (MOF), challenged campaign finance limitations in the Oxnard City Code, alleging they violated the First Amendment. The limitations, adopted by the City of Oxnard, California, primarily affected Aaron Starr, MOF's President, who had a history of receiving large contributions and challenging the City Council's policies. Starr had previously led recall efforts against the City Council and ran for Mayor, relying on larger-dollar contributions.The United States District Court for the Central District of California granted summary judgment in favor of the City, upholding the campaign finance limitations. MOF appealed the decision, arguing that the limitations were designed to target and suppress Starr's political activities rather than to prevent corruption.The United States Court of Appeals for the Ninth Circuit reviewed the case and found significant "danger signs" of invidious discrimination against Starr. The court noted that the legislative record and the practical impact of the limitations disproportionately affected Starr, who had been a vocal critic of the City Council. The court also found that the City's justification for the limitations, based on a 2010 corruption scandal, was tenuous and unrelated to campaign contributions.The Ninth Circuit concluded that the contribution limits were not narrowly tailored to the City's interest in preventing quid pro quo corruption. Instead, the limits appeared to be more closely drawn to suppress Starr's political activities. As a result, the court reversed the district court's decision and remanded with instructions to grant summary judgment in favor of MOF, holding that the per-candidate aggregate contribution limitations in the Oxnard City Code violated the First Amendment. View "MOVING OXNARD FORWARD, INC. V. ASCENSION" on Justia Law

Grand Canyon University (GCU), a private university in Arizona, applied to the U.S. Department of Education to be recognized as a nonprofit institution under the Higher Education Act of 1965 (HEA). The Department denied GCU’s application, despite GCU having obtained 26 U.S.C. § 501(c)(3) recognition from the IRS as a tax-exempt organization. The Department concluded that GCU did not meet the operational test’s requirement that both the primary activities of the organization and its stream of revenue benefit the nonprofit itself.The U.S. District Court for the District of Arizona granted summary judgment in favor of the Department, upholding the denial of GCU’s application. The court found that the Department’s decision was not arbitrary and capricious or contrary to law. GCU appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that the Department applied the wrong legal standards in evaluating GCU’s application. Specifically, the Department incorrectly relied on IRS regulations that impose requirements beyond those of the HEA. The correct HEA standards required the Department to determine whether GCU was owned and operated by a nonprofit corporation and whether GCU satisfied the no-inurement requirement. The Department’s failure to apply these correct legal standards necessitated that its decision be set aside.The Ninth Circuit reversed the judgment of the district court and remanded the case with instructions to set aside the Department’s denials and to remand to the Department for further proceedings consistent with the correct legal standards under the HEA. View "GRAND CANYON UNIVERSITY V. CARDONA" on Justia Law

The Office of Foreign Assets Control (OFAC), a part of the United States Department of Treasury, froze the assets of Al Haramain Islamic Foundation, Oregon (AHIF-Oregon), a non-profit organization, and designated AHIF-Oregon as a "specially designated global terrorist" pursuant to Executive Order No. 13,224. AHIF-Oregon eventually filed an action asserting that the OFAC violated a variety of its statutory and constitutional rights. The Multicultural Association of Southern Oregon, which the government had not accused of supporting terrorism, challenged certain laws that barred it from providing services to designated entities such as the AHIF-Oregon. With the exception of one claim not at issue on appeal, the district court granted summary judgment to OFAC. The court affirmed the district court's ruling that substantial evidence supported OFAC's redesignation of AHIF-Oregon as a specially designated global terrorist, and the court affirmed the district court's rejection of AHIF-Oregon's due process claims. The court reversed the district court's rejection of AHIF-Oregon's Fourth Amendment claim and remanded for the district to determine what judicial relief, if any, was available. Finally, the court reversed the district court's dismissal of plaintiffs' First Amendment claim.

Plaintiffs alleged that defendant, a non-profit Christian organization operating a residential drug treatment program and two homeless shelters, engaged in religious discrimination in providing shelter and residential recovery services in violation of the Fair Housing Act (FHA), 42 U.S.C. 3601-3631. At issue was the extent of the protection afforded by the FHA against religious discrimination. The court affirmed summary judgment for defendant and held that, even assuming that section 3604(a) and (b) applied to defendant's homeless shelters, the FHA's religious exemption permitted the practices challenged by plaintiffs in this case. Therefore, the court expressed no view on the merits of defendant's arguments about the proper scope of section 3604(a) and (b) and the proper definition of "residence" in section 3602(b). The court also affirmed summary judgment on the sex discrimination claim because there was no evidence to establish that defendant treated the men in its parallel drug treatment program any differently than it treated the women and the interference, coercion, or intimidation claim claim because plaintiffs had not exercised a right granted to them by section 3604.