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

Peyman Roshan, a lawyer and real estate broker, had his law license suspended by the California Supreme Court in 2021 for misconduct. Following this, the California Department of Real Estate (DRE) initiated a reciprocal disciplinary proceeding against his real estate license. Roshan filed a federal lawsuit against the DRE, alleging constitutional violations and seeking to enjoin the DRE's disciplinary action.The United States District Court for the Northern District of California dismissed Roshan's lawsuit, citing the Younger abstention doctrine, which prevents federal courts from interfering with certain ongoing state proceedings. The district court held that the DRE's disciplinary proceeding was quasi-criminal in nature and that Roshan could raise his federal claims during the judicial review of the DRE action.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 the district court correctly applied the Younger abstention doctrine. The court noted that the state proceedings were ongoing, involved important state interests, and allowed Roshan to raise his federal claims. The court also determined that the DRE proceeding was quasi-criminal because it was initiated by a state agency following an investigation, involved formal charges, and aimed to determine whether Roshan should be sanctioned by suspending or revoking his real estate license.The Ninth Circuit concluded that all the requirements for Younger abstention were met and that Roshan had not demonstrated any bad faith, harassment, or extraordinary circumstances that would make abstention inappropriate. Therefore, the district court's decision to abstain from hearing the case was proper, and the dismissal of Roshan's lawsuit was affirmed. View "ROSHAN V. MCCAULEY" on Justia Law

Jose Trinidad Martinez Santoyo was sought for extradition to Mexico to face charges of intentional aggravated homicide. In January 2014, a Mexican judge issued an arrest warrant for Santoyo, alleging he shot a man twice in the head after an argument. Mexico requested his provisional arrest in November 2018, and the United States filed a complaint in August 2021. Santoyo was arrested in May 2022 and released on bail in November 2022. Mexico formally requested his extradition in July 2022, providing various supporting documents. A magistrate judge certified the extradition in February 2023, and Santoyo challenged this certification via a habeas corpus petition.The United States District Court for the Eastern District of California denied Santoyo's habeas corpus petition. Santoyo argued that the extradition treaty between the United States and Mexico incorporated the Sixth Amendment's Speedy Trial Clause, contending that the delay between the 2014 arrest warrant and the 2022 extradition request violated his speedy trial rights. The district court rejected this argument, holding that the treaty's "lapse of time" provision referred only to statutes of limitations, not to the Sixth Amendment's speedy trial protections.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 "lapse of time" language in the extradition treaty does not incorporate the Sixth Amendment Speedy Trial Clause. The court emphasized that extradition proceedings are not criminal prosecutions and that the treaty's language refers to statutes of limitations rather than the constitutional right to a speedy trial. The court also noted that the judiciary's role in extradition is limited and that issues of delay are more appropriately addressed by the Secretary of State. View "SANTOYO V. BOYDEN" on Justia Law

John Walthall, while awaiting sentencing for a fraud conviction, solicited a fellow inmate to arrange for hit men to murder the judge, investigators, and attorneys involved in his case. The inmate reported Walthall's request to authorities, leading to Walthall's conviction for solicitation to commit a crime of violence under 18 U.S.C. § 373(a). Walthall argued that the evidence was insufficient because he had no direct contact with the hit men, who did not exist.The United States District Court for the Central District of California found Walthall guilty, but the jury was initially unable to reach a verdict. After a retrial, Walthall was convicted, but the Ninth Circuit Court of Appeals reversed and remanded for a new trial, citing errors in denying Walthall the right to represent himself. On remand, the district court evaluated Walthall's competency to stand trial and represent himself, ultimately concluding that he was competent to stand trial but not to represent himself due to severe mental illness.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed Walthall's conviction. The court held that 18 U.S.C. § 373(a) does not require direct communication with the person solicited or that the person solicited actually exists. The evidence was sufficient to support the conviction, as Walthall's intent and actions strongly corroborated his intent for someone to commit violence. The court also rejected Walthall's challenges to the jury instructions and the district court's finding that he was incapable of representing himself. The court found no error in the district court's sentencing calculation based on the maximum sentence for soliciting murder. The Ninth Circuit affirmed the district court's judgment. View "USA V. WALTHALL" on Justia Law

Sergeant Dan Ponder of the Riverside County Sheriff’s Department responded to a call about someone destroying property with a bat. Upon arrival, he encountered Clemente Najera-Aguirre, who matched the suspect's description. Ponder commanded Najera to drop the bat, but Najera did not comply and approached Ponder. Ponder pepper-sprayed Najera twice, but it was ineffective. Ponder then fired six shots, with the final two bullets, which were fatal, striking Najera in the back as he turned away.The plaintiffs, Najera’s children, sued Ponder and Riverside County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. The United States District Court for the Central District of California denied Ponder’s motion for summary judgment on the Fourth Amendment claim, and the Ninth Circuit affirmed this decision on interlocutory appeal. After a five-day trial, the jury found in favor of the plaintiffs, awarding $10 million in damages. Ponder’s post-trial motion for judgment as a matter of law, including a claim for qualified immunity, was denied by the district court.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that Ponder did not waive his qualified immunity defense and that the jury’s verdict established that Ponder violated Najera’s Fourth Amendment rights. The court found that Ponder’s use of deadly force was not justified as Najera posed no immediate threat to Ponder or others, and the law clearly established that such force was unlawful. The court emphasized that Ponder’s actions, including shooting Najera in the back, did not entitle him to qualified immunity. View "ESTATE OF AGUIRRE V. COUNTY OF RIVERSIDE" on Justia Law

During a traffic stop in Nevada, Oak Porcelli was found with over a million dollars in cash, which he claimed was "petty cash" for a non-existent movie production company. The Drug Enforcement Agency (DEA) seized the money, suspecting it was linked to drug trafficking, and the government filed a civil forfeiture complaint.Porcelli filed a claim asserting ownership of the money and moved to suppress evidence from the traffic stop, arguing lack of probable cause. The government served interrogatories under Supplemental Rule G(6) to determine Porcelli's relationship to the money. Porcelli's responses were vague, and despite multiple court orders, he refused to provide more detailed answers. The district court struck his claim and granted the government default judgment of forfeiture.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Rule G(6) allows the government to seek discovery about a claimant's standing at any time during the litigation, not just at the pleading stage. The court found that Porcelli's standing was reasonably in dispute and that his vague responses to the interrogatories were insufficient. The court ruled that the district court did not abuse its discretion in striking Porcelli's claim for failing to comply with discovery orders. The court emphasized that while the government has the burden to prove the money is subject to forfeiture, claimants must still provide some evidence of their standing.The Ninth Circuit affirmed the district court's orders, upholding the default judgment of forfeiture against the currency. View "USA V. $1,106,775 IN US CURRENCY" on Justia Law

Plaintiffs, who were allegedly sexually assaulted or harassed by Uber drivers, filed individual lawsuits against Uber Technologies, Inc. across various districts. They claimed Uber failed to take reasonable measures to prevent such misconduct, asserting negligence, misrepresentation, products liability, and vicarious liability. Plaintiffs argued that Uber was aware of the issue since at least 2014 but did not implement adequate safety measures, such as proper background checks, emergency notifications, and effective responses to complaints.The Judicial Panel on Multidistrict Litigation (JPML) centralized these cases in the Northern District of California for coordinated pretrial proceedings under 28 U.S.C. § 1407. Uber opposed the centralization, arguing that their terms of use included a collective action waiver that precluded such a transfer and that the cases did not share sufficient common factual questions to warrant centralization. The JPML found that the cases did involve common factual questions and that centralization would eliminate duplicative discovery, prevent inconsistent pretrial rulings, and conserve resources.The United States Court of Appeals for the Ninth Circuit reviewed Uber's petition for a writ of mandamus challenging the JPML's order. The court held that Uber had not demonstrated that the JPML committed a clear error of law or a clear abuse of discretion. The court found that the JPML acted within its broad discretion in determining that the cases presented common questions of fact and that centralization would promote the just and efficient conduct of the actions. The court also rejected Uber's argument regarding the collective action waiver, stating that Section 1407 grants the JPML the authority to centralize cases regardless of private agreements to the contrary. Consequently, the Ninth Circuit denied Uber's petition for a writ of mandamus. View "UBER TECHNOLOGIES, INC. V. UNITED STATES JUDICIAL PANEL ON MULTIDISTRICT LITIGATION" on Justia Law

Lars Jensen, a math professor at Truckee Meadows Community College (TMCC), voiced concerns about a policy change to the math curriculum standards. He criticized the new co-requisite policy, which placed students needing remedial instruction in college-level classes, arguing it lowered academic standards. Following his criticism, Jensen faced several adverse actions, including reprimands, negative performance reviews, and a termination hearing.The United States District Court for the District of Nevada dismissed Jensen’s claims, including First Amendment retaliation, procedural due process, and equal protection violations. The court held that Jensen’s First Amendment claim was barred by qualified immunity and that his official capacity claim was barred by sovereign immunity. The court also found that Jensen failed to identify a protected interest for his due process claim and did not allege membership in a discrete class for his equal protection claim. The court dismissed all claims with prejudice and denied leave to amend.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Jensen’s First Amendment retaliation claim. The appellate court held that Jensen’s criticism of the curriculum changes addressed a matter of public concern and was protected speech related to scholarship or teaching. The court found that the adverse actions against Jensen were motivated by his speech and that the state had not shown a substantial disruption to outweigh his First Amendment rights. The court also held that the Administrators were not entitled to qualified immunity and that Jensen’s official capacity claim for prospective relief was not barred by sovereign immunity. The court affirmed the dismissal of Jensen’s due process and equal protection claims but reversed the denial of leave to amend, remanding for further proceedings. View "JENSEN V. BROWN" on Justia Law

John Hudnall, a former financial advisor, applied for disability benefits under the Social Security Act, claiming he had been unable to work since May 1, 2015, due to major depressive disorder, anxiety, and insomnia. His application included a function report from his wife, Miyuki Sato, detailing his limitations in daily activities and self-care. Despite this, the Social Security Administration denied his application and request for reconsideration. Hudnall then sought a hearing before an Administrative Law Judge (ALJ), who also denied his claim, finding him not disabled based on medical evidence and Hudnall's self-reported activities, without explicitly addressing Sato's lay evidence.Hudnall appealed to the United States District Court for the Northern District of California, which granted summary judgment in favor of the Social Security Administration. Hudnall then appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reviewed the case and affirmed the district court's judgment. The court held that under the Social Security Administration's new regulations, effective March 27, 2017, ALJs are no longer required to provide germane reasons for discounting lay witness testimony. The court found that these regulations, which state that ALJs are not required to articulate how they considered evidence from nonmedical sources, are within the Commissioner of Social Security's broad authority and are not arbitrary and capricious. Consequently, the ALJ did not err in discounting Sato's evidence without explanation. The court resolved all other issues in a concurrently filed memorandum disposition. View "HUDNALL V. DUDEK" on Justia Law

Farmers Direct Property and Casualty Insurance Company filed a declaratory judgment action against Dennis Perez, seeking a declaration that it no longer had a duty to defend or indemnify Perez under an auto insurance policy in connection with an automobile accident involving Victor Montez. Perez had been uncooperative in his defense in the underlying state court tort action filed by the Montezes, leading Farmers Direct to claim that Perez breached the policy's cooperation clause. The Montezes intervened and moved to set aside the default judgment entered against Perez, arguing that the district court lacked subject matter jurisdiction because the amount in controversy did not meet the statutory requirement.The United States District Court for the Central District of California granted the Montezes' motion, vacating the default judgment on the grounds that the amount in controversy was limited to the policy's $25,000 face amount, which did not satisfy the jurisdictional threshold of over $75,000. Farmers Direct appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's order. The appellate court held that the district court erred in determining that the value of the declaratory judgment action was limited to the policy's $25,000 maximum liability. The Ninth Circuit found that there was at least an arguable basis that the amount in controversy was satisfied by considering either the potential excess liability of the underlying tort claim or Farmers Direct's anticipated future defense fees and costs, or both. The appellate court concluded that the judgment was not void for lack of subject matter jurisdiction and remanded the case for further proceedings. View "FARMERS DIRECT PROPERTY AND CASUALTY INSURANCE COMPANY V. MONTEZ" on Justia Law

A church in Washington, Cedar Park Assembly of God, challenged the state's Reproductive Parity Act (Parity Act), which mandates insurance carriers to cover all federally approved contraceptives and, if maternity care is included, abortions. The church argued that this law violated its First Amendment rights and religious autonomy because it could not find a comparable health plan that excluded abortion coverage after its insurer, Kaiser Permanente, stopped offering such a plan.The United States District Court for the Western District of Washington granted summary judgment in favor of the state officials, Myron Kreidler and Jay Inslee, who were sued in their official capacities. The district court found that the church did not have standing to challenge the Parity Act because it could not demonstrate that its inability to obtain a suitable health plan was directly caused by the Act.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo and vacated the district court's summary judgment, remanding with instructions to dismiss the action for lack of standing. The Ninth Circuit held that Cedar Park Assembly of God failed to establish that its injury was traceable to the Parity Act or that invalidating the Act would redress its injury. The court noted that Washington's conscientious-objection statute allows insurers to accommodate religious objections, and nothing in the Parity Act prevents insurers from offering plans that exclude abortion coverage. The court concluded that the church's injury was due to the independent decisions of insurers, not the Parity Act, and thus, the church lacked standing to sue. View "CEDAR PARK ASSEMBLY OF GOD OF KIRKLAND, WASHINGTON V. KREIDLER" on Justia Law