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

Several individuals living within a five-mile radius of the Seattle-Tacoma Airport sued two major airlines and the Port of Seattle. They alleged that pollution from aircraft takeoffs and landings caused harm to their health and property, particularly from particulate matter and other pollutants released by aircraft engines and fuselages. Plaintiffs claimed the defendants had knowledge of studies linking these pollutants to negative health outcomes and property devaluation but failed to remediate or prevent further pollution. The affected community was described as disproportionately composed of minority, immigrant, and low-income residents.The plaintiffs initially brought their case in King County Superior Court, but the defendants removed it to the United States District Court for the Western District of Washington. The plaintiffs advanced state tort and constitutional claims, seeking various remedies including damages, injunctive relief, and remediation. The defendants moved to dismiss, arguing that the claims were a collateral attack on federal agency actions, were expressly and impliedly preempted by federal law, and failed to state a claim. The district court denied the motions, finding that the complaint did not directly challenge any specific agency order and that preemption was not clearly established at this stage. The district court certified its order for interlocutory appeal.Reviewing the case on interlocutory appeal, the United States Court of Appeals for the Ninth Circuit held that the district court properly exercised jurisdiction because the collateral attack doctrine did not apply; defendants could not identify any specific agency orders inescapably implicated by the plaintiffs’ claims. However, the court held that the claims were expressly preempted by Section 233 of the Clean Air Act, which bars states from enforcing any emission standards for aircraft pollutants unless identical to federal standards. The court reversed the district court’s order denying the motion to dismiss and remanded the case. View "CODONI V. PORT OF SEATTLE" on Justia Law

The case centers on an incident during a Delta Air Lines domestic flight, where a passenger’s behavior prompted concerns among fellow travelers and flight attendants. After an off-duty pilot and other passengers reported the passenger’s conduct as suspicious, the lead flight attendant, following consultation with the captain, approached the passenger and attempted to ask him to remain seated. This interaction escalated into a physical confrontation, leading the flight attendant to request assistance from a federal law enforcement agent onboard. The agent, with the flight attendant’s help, restrained the passenger until the plane landed. The passenger later alleged that he suffered physical and emotional injuries as a result of the restraint.At trial in the United States District Court for the Central District of California, a jury found in favor of the passenger, awarding him substantial damages for bodily and emotional injuries. However, the district court vacated the verdict, citing excessive damages and the interdependence of liability and damages. The court subsequently granted summary judgment for Delta Air Lines, concluding that the airline was immune from liability under the Aviation and Transportation Security Act (ATSA) for any injuries sustained after the flight attendants reported the passenger’s behavior to law enforcement.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The Ninth Circuit affirmed the district court’s grant of summary judgment, holding that ATSA immunity applies not only to the initial disclosure of suspicious activity to law enforcement but also to subsequent conduct stemming from law enforcement’s decisions following such disclosure. The court found no genuine dispute of material fact regarding whether the passenger’s conduct was objectively suspicious or whether Delta was solely responsible for the injuries. As Delta was immune for all physical injuries, the passenger could not recover for any alleged emotional injuries under the Montreal Convention. View "BANDARY V. DELTA AIR LINES, INC." on Justia Law

A helicopter owned and operated by the Huntington Beach Police Department crashed in 2022, resulting in the death of Officer Nicholas Vella and serious injury to Officer RJ Garwood. The plaintiffs alleged that the crash was caused by a defect in the helicopter’s stability augmentation system. The helicopter, a model MD520N, was manufactured by The Boeing Company in 1998 and delivered to the police department that same year. It had a seating capacity of five and was type and airworthiness certified by the Federal Aviation Administration (FAA).The plaintiffs initially brought their claims for strict products liability, breach of warranties, and negligence in California state court. The case was removed to the United States District Court for the Central District of California on the basis of diversity jurisdiction. The defendants, including The Boeing Company and MacD Helicopters, moved to dismiss, arguing that the claims were barred by the General Aviation Revitalization Act’s (GARA) 18-year statute of repose. The plaintiffs contended that GARA did not apply to “public aircraft” such as those owned by governmental entities. The district court rejected the plaintiffs’ arguments, found that the helicopter met GARA’s definition of “general aviation aircraft,” and granted the motions to dismiss. The court certified its decision for interlocutory appeal and stayed further proceedings.The United States Court of Appeals for the Ninth Circuit considered whether GARA’s statute of repose applied to the police helicopter. The court held that the statute’s definition of “general aviation aircraft” includes government-owned aircraft, as long as the statutory requirements are met. The panel expressly rejected the argument that the Federal Aviation Act’s “public aircraft” definition is incorporated into GARA and concluded that GARA contains no “public aircraft” exception. The Ninth Circuit affirmed the district court’s dismissal of the lawsuit. View "VELLA V. MACD HELICOPTERS, INC." on Justia Law

California officials challenged a determination by the Federal Motor Carrier Safety Administration (FMCSA) that California’s meal and rest break (MRB) rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted by federal law. The MRB rules require employers to provide drivers with specified meal and rest periods during the workday. The FMCSA concluded that these state rules regulated commercial motor vehicle safety, were more stringent than federal hours-of-service (HOS) regulations, and imposed requirements not found in federal law.Previously, in 2019, the American Bus Association petitioned the FMCSA to preempt California’s MRB rules for passenger-carrying drivers. After public notice and comment, the FMCSA issued a final order in 2020 preempting these rules, finding they added no measurable safety benefit beyond federal HOS rules, were incompatible with federal regulations, and placed an unreasonable burden on interstate commerce. California officials petitioned the United States Court of Appeals for the Ninth Circuit for review of the FMCSA’s preemption decision.The United States Court of Appeals for the Ninth Circuit reviewed the FMCSA’s action under the highly deferential standard of the Administrative Procedure Act. It held that its earlier decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021), foreclosed California’s main arguments and confirmed that the FMCSA had authority to preempt the MRB rules. The court also held that the FMCSA’s determination that the MRB rules imposed an unreasonable burden on interstate commerce was supported by the administrative record and not arbitrary or capricious. The petition for review was denied, and the FMCSA’s preemption determination was upheld. View "PEOPLE OF THE STATE OF CAL. V. FMCSA" on Justia Law

The case concerns a fatal helicopter crash during a sightseeing tour in Hawaii, resulting in the deaths of all aboard, including the plaintiffs’ daughter. The helicopter, manufactured by Robinson Helicopter Company in 2000, had its main rotor hub and blades replaced with new, identical parts from Robinson in December 2018, which was over eighteen years after the helicopter’s initial delivery. The plaintiffs alleged that defects in the replaced rotor hub and blades caused the crash, and brought claims for negligence, strict products liability, and failure to warn.The United States District Court for the District of Hawaii heard the case first. Robinson invoked the General Aviation Revitalization Act of 1994 (GARA), which generally bars actions against manufacturers eighteen years after delivery of the aircraft. The plaintiffs argued for exceptions under GARA’s “rolling provision”—which restarts the repose period for newly replaced parts—and the “fraud exception”—which removes the bar if the manufacturer concealed or misrepresented material information to the FAA. The district court granted summary judgment for Robinson, holding that the rolling provision did not apply because the replacement parts were not substantively altered from the originals, and that the plaintiffs failed to plead fraud with the necessary specificity. The court also denied the plaintiffs’ motion to further amend their complaint.On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court erred in requiring a “substantive alteration” for the rolling provision to apply, as GARA only requires that a new part replaces an old one. The Ninth Circuit reversed the grant of summary judgment in part and remanded for a new causation analysis regarding the replaced parts. However, the court affirmed the lower court’s determinations that the plaintiffs failed to meet the requirements for the fraud exception and that denying leave to amend was not an abuse of discretion. View "MCAULIFFE V. ROBINSON HELICOPTER COMPANY" on Justia Law

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period.This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

Three California-based truck drivers who worked for a national transportation company challenged the legality of their employer’s compensation system. The drivers alleged that the company’s pay plan, which combined hourly wages with a bonus based on certain activities, violated California’s Labor Code by failing to properly compensate for nonproductive time and by not reimbursing necessary business expenses, such as personal cell phone use. They also claimed the company failed to provide accurate wage statements and sought penalties under the Private Attorneys General Act (PAGA) and California’s Unfair Competition Law.After the case was removed from state court, the United States District Court for the Central District of California denied class certification and granted summary judgment to the employer on most claims. The court found that the pay plan qualified for a statutory “safe harbor” because it paid at least minimum wage for all hours worked, with additional bonuses for certain activities, and thus did not require separate compensation for nonproductive time. The court also found no evidence that the employer knew or should have known about any off-the-clock work. The only claims that proceeded to trial were for failure to reimburse business expenses. At trial, the jury found in favor of the employer, and the court entered judgment accordingly, also awarding costs to the employer.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the employer’s pay plan met the requirements of California Labor Code § 226.2(a)(7)’s safe harbor, as it paid at least minimum wage for all hours worked and provided additional bonuses. The court also found no genuine dispute of material fact regarding off-the-clock work or wage statement violations, and it upheld the district court’s evidentiary rulings, jury instructions, and award of costs. View "WILLIAMS V. J.B. HUNT TRANSPORT, INC." on Justia Law

Ali Bahreman, a flight attendant for Allegiant Air, challenged the Collective Bargaining Agreement (CBA) between Allegiant and the Transport Workers Union (Union). The CBA required employees to either pay union dues or agency fees to maintain seniority-based bidding privileges for work schedules. Bahreman chose not to pay any fees and subsequently lost his bidding privileges. He argued that this arrangement violated the Railway Labor Act (RLA) by coercing employees to join the Union, deviating from the employment-termination remedy, and breaching the Union's duty of fair representation.The United States District Court for the District of Nevada granted summary judgment in favor of Allegiant and the Union. The court found that the CBA did not violate the RLA's anti-coercion provision, as it did not induce employees to join the Union. The court also held that the RLA does not prohibit collective bargaining agreements with terms other than those explicitly permitted by the Act. Additionally, the court determined that the Union did not breach its duty of fair representation, as it enforced the CBA equally among all members of the bargaining unit.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the RLA does not prohibit a collective bargaining agreement that conditions seniority-based bidding privileges on the payment of union dues or agency fees. The court found that the CBA did not induce union membership, as it treated union members and nonmembers alike regarding payment requirements. The court also concluded that the CBA's terms were permissible under the RLA and that the Union did not act arbitrarily, discriminatorily, or in bad faith in enforcing the agreement. View "Bahreman v. Allegiant Air, LLC" on Justia Law

Mendocino Railway, a California corporation, owns and operates a railroad line known as the "Skunk Train" between Fort Bragg and Willits, California. The City of Fort Bragg and the California Coastal Commission sought to regulate the use and maintenance of the Railway's properties within the City, which the Railway resisted, claiming federal preemption under the Interstate Commerce Commission Termination Act (ICCTA). The City filed a state court action seeking declaratory and injunctive relief to compel the Railway to comply with local regulations. The Railway argued that federal law preempted these local regulations. Subsequently, the Railway filed a federal lawsuit seeking a declaration that the City's and Commission's regulatory actions were preempted by federal law and an injunction to prevent interference with its operations.The Mendocino County Superior Court overruled the Railway's demurrer, which argued that federal law preempted all local regulations. The Railway's subsequent petitions to the California Court of Appeal and the California Supreme Court were unsuccessful. The Railway then filed an answer in the state court, asserting federal preemption as an affirmative defense. Meanwhile, the Commission intervened in the state court action, seeking a declaration that the Coastal Act and local coastal program applied to the Railway's activities and were not preempted by federal law. The Railway also attempted to remove the state action to federal court, but the district court remanded it back to state court.The United States Court of Appeals for the Ninth Circuit reviewed the district court's dismissal of the Railway's federal lawsuit under the Colorado River doctrine, which allows federal courts to abstain from exercising jurisdiction in favor of parallel state court proceedings. The Ninth Circuit affirmed the district court's dismissal, finding that the state court proceedings were sufficiently parallel to the federal action and that considerations of avoiding piecemeal litigation, forum shopping, and the order in which the forums obtained jurisdiction supported the dismissal. The court held that the state court could adequately protect the Railway's rights and that the federal preemption issue could be resolved in the state court proceedings. View "MENDOCINO RAILWAY V. AINSWORTH" on Justia Law

Curtis Rookaird, represented by Paul Parker, was terminated by BNSF Railway Company after performing an air-brake test, which he argued was a protected activity under the Federal Railroad Safety Act (FRSA). Rookaird claimed his termination was retaliatory. Initially, a jury found in Rookaird’s favor, but the Ninth Circuit vacated the verdict and remanded the case to the district court to reconsider whether the air-brake test contributed to BNSF’s decision to terminate him. On remand, the district court conducted a bench trial and ruled in favor of BNSF, concluding that while the air-brake test contributed to the termination, it did so "very little."The district court found that BNSF had conceded the air-brake test contributed to Rookaird’s termination but ruled that BNSF was entitled to an affirmative defense by showing the test contributed minimally. The court also upheld BNSF’s evidentiary rulings, excluding certain testimony and admitting comparator evidence. Rookaird appealed, arguing the district court misapplied the FRSA and erred in its evidentiary rulings.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s evidentiary rulings, finding no abuse of discretion. However, it vacated the district court’s judgment on the affirmative defense issue. The Ninth Circuit held that under the FRSA, an employer must prove by clear and convincing evidence that it would have terminated the employee absent the protected activity, not merely that the protected activity contributed "very little" to the decision. The case was remanded for the district court to determine if BNSF met this burden, given that the air-brake test could not contribute even in part to the termination decision. View "Parker v. BNSF Railway Co." on Justia Law