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

Eight firefighters employed by a regional fire and rescue agency in Washington State requested religious exemptions from a COVID-19 vaccine mandate issued in August 2021 by the state’s governor, which required healthcare providers to be vaccinated. The fire agency, which provides emergency medical and fire services to a large population, including a state prison, allowed employees to seek religious accommodations. After reviewing the requests and consulting with union representatives, the agency determined it could not accommodate unvaccinated firefighters in their roles without imposing an undue hardship on its operations, citing health and safety concerns, operational burdens, and potential financial risks. The firefighters were offered the option to use accrued leave or take a leave of absence, with the possibility of returning if the mandate changed.The firefighters sued in the United States District Court for the Western District of Washington, alleging violations of Title VII of the Civil Rights Act and the Washington Law Against Discrimination for failure to accommodate their religious beliefs. The district court assumed the firefighters had bona fide religious objections but found that accommodating their requests would impose an undue hardship on the agency, given the increased risk of COVID-19 transmission, the large number of exemption requests, and the inadequacy of proposed alternatives such as masking and testing. The court granted summary judgment in favor of the fire agency.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that, under the standard clarified in Groff v. DeJoy, an employer demonstrates undue hardship when the burden of accommodation is substantial in the context of its business. The court found that the fire agency had shown substantial health, operational, and financial costs associated with accommodating the exemption requests, and that the proposed alternatives were insufficient. The summary judgment for the agency was affirmed. View "PETERSEN V. SNOHOMISH REGIONAL FIRE AND RESCUE" on Justia Law

Michael McNeil, an incarcerated individual at Ely State Prison, was accused of smuggling drugs into the facility via the mail system. During his preliminary disciplinary hearing, McNeil requested access to the evidence against him, including the mail and a positive drug test result from the envelopes’ address labels, but his request was denied. At a subsequent formal hearing, a disciplinary committee found him guilty, resulting in the loss of statutory good time credits, canteen privileges, and a referral for criminal prosecution. After his appeals through the prison’s grievance process were denied, McNeil filed a lawsuit under 42 U.S.C. § 1983, alleging that prison officials violated his Fourteenth Amendment due process rights.The United States District Court for the District of Nevada reviewed cross-motions for summary judgment. The court partially granted McNeil’s motion, finding that his due process rights were violated when he was denied access to certain evidence, but identified a genuine dispute regarding other evidence requests. The court denied the defendants’ motion for summary judgment on qualified immunity, holding that it was clearly established that McNeil had a constitutional right to access the evidence against him. The order was entered on the civil docket on May 22, 2023.The United States Court of Appeals for the Ninth Circuit reviewed the case after the defendants filed a notice of appeal 150 days following the district court’s order. The Ninth Circuit held that 28 U.S.C. § 2107(a) requires a notice of appeal to be filed within 30 days after entry of an order denying qualified immunity. The court rejected the defendants’ argument that the Federal Rules of Civil and Appellate Procedure extended the appeal period to 180 days due to the absence of a separate judgment document. The Ninth Circuit concluded that the appeal was untimely and dismissed it for lack of jurisdiction. View "MCNEIL V. GITTERE" on Justia Law

Robinhood Markets, Inc., an online brokerage firm, experienced a surge in business during early 2021 due to increased trading in “meme stocks” and Dogecoin. This activity declined sharply in the second quarter of 2021, leading to significant drops in key financial metrics and performance indicators. In July 2021, Robinhood conducted an initial public offering (IPO) and issued a registration statement that included limited information about its second-quarter performance. After the IPO, Robinhood released its full second-quarter results, which revealed substantial declines and led to a drop in its stock price. Plaintiffs, representing a class of investors, alleged that Robinhood’s registration statement omitted material information about these declines, violating Sections 11, 12, and 15 of the Securities Act of 1933.The United States District Court for the Northern District of California dismissed the plaintiffs’ claims with prejudice. The district court found that Robinhood and its co-defendants were not liable under the Securities Act for failing to disclose the pre-IPO declines in key performance indicators and certain revenue sources. The court also held that there was no actionable omission regarding the increased percentage of Robinhood’s revenue attributable to speculative trading.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The Ninth Circuit held that the district court applied incorrect legal standards to the plaintiffs’ theories under Section 11’s “misleading” prong and Item 303 of Regulation S-K. The appellate court clarified that, in this context, Sections 11 and 12 require disclosure of all material information, and rejected the “extreme departure” test used by the district court. The court vacated the dismissal as to these theories and remanded for further proceedings. However, the Ninth Circuit affirmed the district court’s dismissal of the claim based on Item 105 of Regulation S-K, finding no duty to provide a breakdown of revenue sources for the relevant period. View "Sodha v. Golubowski" on Justia Law

Hundreds of thousands of Venezuelan nationals living in the United States received Temporary Protected Status (TPS), which allowed them to work and protected them from deportation due to ongoing humanitarian crises in Venezuela. In January 2025, the Secretary of Homeland Security extended TPS for Venezuelans through October 2026, consolidating two prior designations to streamline the process. Shortly after, a new Secretary, following a change in administration, attempted to vacate this extension and terminate TPS for one group of Venezuelan nationals, citing confusion and alleged improvements in Venezuela’s conditions. This abrupt reversal threatened TPS holders with imminent loss of status, employment, and the risk of deportation.The National TPS Alliance and several individual TPS holders filed suit in the United States District Court for the Northern District of California, seeking to restore the extension. The district court granted preliminary relief, postponing the effective dates of the vacatur and termination notices nationwide under the Administrative Procedure Act (APA), finding that plaintiffs were likely to succeed on the merits, would suffer irreparable harm without relief, and that the balance of equities and public interest favored postponement.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s order. The Ninth Circuit held that it had jurisdiction to review the preliminary relief and that neither the TPS statute nor 8 U.S.C. § 1252(f)(1) barred judicial review of the Secretary’s authority. The court concluded that the Secretary lacked statutory authority to vacate a prior extension of TPS, as the statute provides specific procedures for designation, extension, and termination, but not for vacatur. The court also found that nationwide relief was necessary to provide complete relief to the plaintiffs. The district court’s order postponing the vacatur and termination of Venezuelan TPS was affirmed. View "National TPS Alliance v. Noem" on Justia Law

The plaintiff purchased a life insurance policy for her son and consistently paid the required premiums. She alleges that the insurer failed to provide the statutory notices and protections mandated by California law before terminating her policy for nonpayment. After missing a payment in 2016, her policy lapsed, and following reinstatement, it was terminated again in 2018 after another missed payment. The plaintiff contends that the insurer’s failure to comply with statutory notice requirements rendered the termination ineffective and that her experience was representative of many other policyholders in California.The United States District Court for the Eastern District of California granted in part the plaintiff’s motion for class certification. The court found that the prerequisites of Federal Rule of Civil Procedure 23(a) were met and certified a class under Rule 23(b)(2) for declaratory and injunctive relief. The certified class included all policy owners or beneficiaries whose policies lapsed for nonpayment without the required statutory notice. The court appointed the plaintiff as class representative but denied, without prejudice, certification for monetary relief under Rule 23(b)(3).The United States Court of Appeals for the Ninth Circuit reviewed the district court’s class-certification order. Relying on its intervening decision in Small v. Allianz Life Insurance Co. of North America, the Ninth Circuit held that to recover for violations of the relevant California statutes, plaintiffs must show not only a statutory violation but also that the violation caused them harm. The court found that the plaintiff was not an adequate class representative for beneficiaries and that her claims were not typical of class members who intentionally allowed their policies to lapse. The Ninth Circuit reversed the district court’s class-certification order and remanded the case for further proceedings. View "Farley v. Lincoln Benefit Life Co." on Justia Law

After failing to pay property taxes on her home in Maricopa County, Arizona, the plaintiff’s tax liens were sold to a private entity, which later foreclosed on the property. The plaintiff did not respond to the foreclosure action, resulting in a default judgment that extinguished her rights to the property. The property was then deeded to the private purchaser, who transferred it to another private party. The plaintiff subsequently challenged the foreclosure, the retention of surplus equity from the sale, and the constitutionality of the Arizona statute that allowed private parties to enforce tax liens without providing just compensation.The United States District Court for the District of Arizona dismissed the plaintiff’s claims, finding that the Rooker-Feldman doctrine deprived it of subject matter jurisdiction. The court reasoned that the plaintiff’s injuries stemmed from the state court’s foreclosure judgment, which had already extinguished her property rights, and thus her federal claims amounted to an impermissible appeal of a state court decision. The court also dismissed her state law claims, except for one over which it declined supplemental jurisdiction.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed in part and reversed in part. The Ninth Circuit held that the Rooker-Feldman doctrine barred the plaintiff’s claims that directly attacked the state court foreclosure judgment, such as those alleging the foreclosure was an unconstitutional taking or excessive fine. However, the court held that claims challenging the defendants’ post-judgment retention of surplus equity were not barred, in light of the Supreme Court’s decision in Tyler v. Hennepin County, which recognized a property owner’s right to excess equity after a tax foreclosure. The court also found that the plaintiff’s facial challenge to the statute was not barred by Rooker-Feldman but was moot due to legislative amendments. The case was remanded for further proceedings on the surviving claims. View "SEARLE V. ALLEN" on Justia Law

Paul Schwartz, while incarcerated at a federal correctional facility in Tucson, alleged that prison officials were deliberately indifferent to his serious medical needs over an eighteen-month period. He experienced a range of severe symptoms, including tachycardia, blood in his urine, and significant thyroid dysfunction, but claimed he received inadequate and delayed medical care despite repeated attempts to seek help. Schwartz specifically alleged that a mid-level practitioner, Ms. Tatad, refused to provide treatment or access to a physician and instructed others to deny him care. He also claimed that the warden and associate warden ignored his efforts to alert them to his condition, resulting in irreversible kidney injury and other long-term health risks.The United States District Court for the District of Arizona initially dismissed several defendants and later granted summary judgment for the remaining defendants. On appeal, the United States Court of Appeals for the Ninth Circuit reversed in part, allowing Schwartz’s claim against Tatad to proceed. After remand, the district court denied Schwartz’s motion to amend his complaint, then later granted Tatad’s motion for judgment on the pleadings, concluding that the Prison Litigation Reform Act (PLRA) constituted a special factor that placed Schwartz’s claim in a new Bivens context, foreclosing a damages remedy.The United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The Ninth Circuit held that Schwartz’s claim was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, which recognized a Bivens remedy for Eighth Amendment claims of deliberate indifference to serious medical needs. The court found that neither the PLRA, the Bureau of Prisons’ Administrative Remedy Program, nor the factual specifics of Schwartz’s case created a new Bivens context. The court also held that the district court abused its discretion in denying Schwartz leave to amend his complaint. View "SCHWARTZ V. MILLER" on Justia Law

After purchasing a collectible from an online retailer, the plaintiff was charged multiple times through his PayPal account for additional items he alleges he did not knowingly subscribe to. He filed a putative class action in California state court against the retailer, asserting claims under California’s False Advertising Law and Unfair Competition Law. Importantly, he sought only equitable restitution and did not pursue damages, even though he conceded that damages were available under California’s Consumer Legal Remedies Act.The defendant removed the case to the United States District Court for the Southern District of California under the Class Action Fairness Act, which was not disputed as a proper basis for federal jurisdiction. The plaintiff then moved to remand, arguing that the federal court lacked “equitable jurisdiction” because he had an adequate remedy at law available, even though he chose not to pursue it. The district court agreed, holding that it could remand for lack of equitable jurisdiction and that the defendant could not waive the defense that an adequate legal remedy was available.On appeal, the United States Court of Appeals for the Ninth Circuit held that district courts do have the authority to remand a removed case to state court for lack of equitable jurisdiction. However, the Ninth Circuit further held that a defendant may waive the adequate-remedy-at-law defense in order to keep the case in federal court. The court vacated the district court’s remand order and sent the case back to allow the defendant the opportunity to perfect its waiver. If the defendant waives the defense, the case may proceed in federal court. View "RUIZ V. THE BRADFORD EXCHANGE, LTD." on Justia Law

A family leased a home within military housing at the Naval Amphibious Base Coronado in California. Shortly after moving in, they experienced persistent water intrusion and mold contamination, which they alleged damaged their property and affected their health. The family reported these issues to the property manager and the public-private entity responsible for the housing, but claimed that remediation efforts were inadequate and that their concerns were dismissed. After further testing confirmed hazardous mold, the family vacated the property and brought state law claims, including negligence and breach of contract, against the property manager, the public-private housing entity, and a mold remediation company.The defendants removed the case from California state court to the United States District Court for the Southern District of California, asserting federal enclave, federal officer, and federal agency jurisdiction. The district court denied the defendants’ motion to dismiss based on derivative sovereign immunity and, after further proceedings, found that it lacked subject matter jurisdiction on all asserted grounds. Specifically, the court determined there was no evidence that the United States had accepted exclusive jurisdiction over the property, that the defendants failed to show a causal nexus between their actions and federal direction, and that the public-private entity was not a federal agency. The district court remanded the case to state court.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the remand order under an exception allowing appellate review when federal officer removal is asserted. The Ninth Circuit held that the district court correctly found no federal enclave jurisdiction because there was no evidence of federal acceptance of exclusive jurisdiction over the property. The court also held that the defendants did not meet the requirements for federal officer or agency jurisdiction. The Ninth Circuit affirmed the district court’s remand to state court. View "CHILDS V. SAN DIEGO FAMILY HOUSING, LLC" on Justia Law

Gladys Perez was convicted in Nevada state court of first-degree murder, child neglect, and child abuse, and sentenced to life in prison with the possibility of parole. After her conviction was affirmed by the Supreme Court of Nevada and became final in May 2012, Perez filed a state post-conviction habeas petition, which tolled the federal one-year limitations period under the Antiterrorism and Effective Death Penalty Act (AEDPA). Her state petition was denied in December 2013, and Perez repeatedly instructed her court-appointed attorney, Bret Whipple, to file an appeal. Whipple failed to communicate with Perez or file the appeal, and did not provide her with the necessary case documents. After months of unsuccessful attempts to contact Whipple, Perez began preparing a federal habeas petition on her own, facing additional obstacles such as limited access to the prison law library, incomplete case files, and delays in obtaining a required financial certificate from prison officials.The United States District Court for the District of Nevada dismissed Perez’s federal habeas petition as untimely, finding that she had not demonstrated the extraordinary circumstances or reasonable diligence required for equitable tolling under AEDPA. The district court concluded that Perez’s efforts to contact her attorney and prepare her petition were insufficient to excuse her late filing.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The Ninth Circuit held that Perez’s abandonment by her post-conviction counsel constituted an extraordinary circumstance that prevented her timely filing, and that she acted with reasonable diligence both before and after the abandonment. The court also found that delays by prison officials in processing her financial certificate further contributed to her late filing. The panel concluded that Perez qualified for equitable tolling and remanded the case for consideration of the merits of her habeas petition. View "PEREZ V. REUBART" on Justia Law