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

An attorney, Daniel Crowe, challenged the requirement to join the Oregon State Bar (OSB), arguing it infringed on his First Amendment right to freedom of association. Crowe objected to statements published by OSB in its magazine, which he felt misrepresented his views. OSB refunded Crowe a portion of his dues used for the publication but did not satisfy his concerns, leading him to file a lawsuit seeking declaratory and injunctive relief, as well as damages.The United States District Court for the District of Oregon initially dismissed Crowe's claims, but the Ninth Circuit Court of Appeals partially reversed this decision, allowing the freedom of association claim to proceed. On remand, the district court granted summary judgment for OSB, holding that the bar's activities were germane to its regulatory purpose and did not violate Crowe's rights. Crowe appealed again.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that OSB is an arm of the state entitled to sovereign immunity, dismissing claims against OSB and for retrospective relief against its officers. However, the court found that Crowe demonstrated an infringement on his freedom of association because OSB's statements in its magazine could reasonably be imputed to its members, including Crowe, and were not related to the bar's regulatory purpose. The court concluded that this infringement did not survive exacting scrutiny.The Ninth Circuit reversed the district court's judgment regarding Crowe's freedom of association claim for prospective equitable relief against individual OSB officers and remanded the case for further proceedings. View "CROWE V. OREGON STATE BAR" on Justia Law

The case involves a challenge to the Hawai‘i Court Records Rules, which mandate that all medical and health records filed in any court proceeding be filed under seal without further judicial order. The plaintiff, Civil Beat Law Center for the Public Interest, argued that this rule is unconstitutionally overbroad under the First Amendment, which grants the public a presumptive right to access court records.The United States District Court for the District of Hawai‘i granted summary judgment in favor of the defendants, the Chief Court Administrators of the Hawai‘i state courts. The district court held that the public does not have a presumptive First Amendment right to access medical and health records, and even if such a right existed, requiring case-by-case litigation to unseal these records did not violate the First Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the First Amendment grants the public a presumptive right to access a substantial portion of the records sealed under Hawai‘i’s mandatory sealing provision. The court found that the state’s interest in protecting individual privacy rights does not justify the categorical sealing of all medical and health records without any case-by-case consideration. The court concluded that the mandatory sealing rule is not the least restrictive means of protecting privacy interests and that case-by-case judicial review would better balance privacy concerns with the public’s right to access.The Ninth Circuit held that the Hawai‘i Court Records Rules are unconstitutionally overbroad because they encroach on the public’s right of access to court records. The court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "CIVIL BEAT LAW CENTER FOR THE PUBLIC INTEREST, INC V. MAILE" on Justia Law

The case involves Kimberly Marroquin, who sued Los Angeles Police Officer DiMaggio Rico and the City of Los Angeles under 42 U.S.C. § 1983, alleging excessive force and negligence after being injured by a less-lethal projectile during a crowd control situation following a Lakers game. Marroquin claimed that the injury caused her substantial physical and emotional harm. The jury found in favor of Marroquin on her excessive force and negligence claims but awarded inconsistent damages: $1.00 against Officer Rico and $1,500,000.00 against the City.The United States District Court for the Central District of California granted a new trial limited to damages under Fed. R. Civ. P. 59(a)(1)(A), citing a miscarriage of justice due to the jury's improper apportionment of damages. The court also denied the defendants' motion for relief from judgment under Fed. R. Civ. P. 60(b)(2), which was based on newly discovered surveillance footage. The court found that the defendants failed to show reasonable diligence in discovering this evidence.The United States Court of Appeals for the Ninth Circuit reviewed the district court's post-trial orders. The Ninth Circuit held that the district court did not abuse its discretion in granting a new trial limited to damages, rejecting the defendants' argument that the liability and damages issues were so interwoven that a damages-only trial violated their Seventh Amendment rights. The court found that the liability issues were distinct and separable from the damages issues and that the jury's confusion was likely due to an improper instruction on the verdict form.The Ninth Circuit also upheld the district court's denial of the Rule 60(b)(2) motion, agreeing that there is no exception to the requirement of reasonable diligence, even if the newly discovered evidence is conclusive. The court affirmed the district court's decisions, maintaining the new trial limited to damages and the denial of relief from judgment based on the newly discovered evidence. View "MARROQUIN V. CITY OF LOS ANGELES" on Justia Law

A resident of the Commonwealth of the Northern Mariana Islands (CNMI) filed a lawsuit seeking a declaratory judgment that the Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States precludes the application of a federal cockfighting prohibition. The plaintiff also sought an injunction to prevent the enforcement of this prohibition. The federal cockfighting prohibition, codified in 7 U.S.C. § 2156 and amended in 2018, made cockfighting illegal in all U.S. jurisdictions, including the CNMI.The U.S. District Court for the Northern Mariana Islands dismissed the complaint with prejudice, finding that the federal cockfighting prohibition applied to the CNMI under the Covenant. The district court determined that 7 U.S.C. § 2156 was applicable to Guam and the several states as required by Covenant § 502, and thus also applicable to the CNMI. The court also found that Covenant § 105, which governs laws enacted after January 9, 1978, did not apply to amendments of laws that existed on that date.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Covenant § 502 governs the applicability of 7 U.S.C. § 2156 and its 2018 Amendment to the CNMI. The court found that § 2156 was applicable to Guam and the several states as of January 9, 1978, and thus applicable to the CNMI. The court also held that even if Covenant § 105 were to govern, the federal cockfighting prohibition would still apply to the CNMI because it is applicable to the several states and does not impermissibly intrude upon the internal affairs of the CNMI. The court concluded that the federal interests in regulating interstate commerce, ensuring the humane treatment of animals, and preventing the spread of avian flu outweighed any intrusion into the CNMI’s internal affairs. The judgment was affirmed. View "SALAS V. USA" on Justia Law

Zohaib Zia, a citizen of Pakistan, entered the United States as a conditional permanent resident based on his marriage to a U.S. citizen, Anum Haq. After their marriage ended in divorce, Zia sought a waiver to remove the conditions on his residency, claiming the marriage was entered into in good faith. U.S. Citizenship and Immigration Services (USCIS) denied his petition, finding the marriage was not in good faith, and terminated his conditional status. The Department of Homeland Security then issued a notice to appear, charging him as removable. Zia renewed his petition before an Immigration Judge (IJ), who also denied it, citing an adverse credibility finding and insufficient evidence of a good faith marriage.The Board of Immigration Appeals (BIA) affirmed the IJ's decision, agreeing with the adverse credibility determination and finding the remaining evidence insufficient to prove a good faith marriage. Zia appealed to the United States Court of Appeals for the Ninth Circuit, arguing that the BIA erred in its findings and that his due process rights were violated due to an incomplete hearing transcript.The Ninth Circuit held that it lacked jurisdiction to review the adverse credibility finding, as such factual determinations are unreviewable under Patel v. Garland. The court also found that while it had limited jurisdiction to review the good faith marriage determination as a mixed question of fact and law, the BIA's decision was not in error. The court concluded that Zia's testimony was of little weight due to the adverse credibility finding, and the remaining evidence did not compel a reversal. Additionally, the court rejected Zia's due process claim, finding no prejudice from the incomplete transcript. The petition for review was dismissed in part and denied in part. View "ZIA V. GARLAND" on Justia Law

Victor Meza-Carmona, born in Mexico to a U.S. citizen mother, Victoria, claimed U.S. citizenship based on his mother's status. Under 8 U.S.C. § 1409(c) (1952), Victoria could transmit citizenship to him only if she had been physically present in the U.S. for a continuous period of one year before his birth. Victoria was born in Los Angeles and baptized in El Paso, Texas, but later moved to Mexico. The case hinges on whether Victoria met the continuous physical presence requirement.The Department of Homeland Security initiated removal proceedings against Meza-Carmona in 2012. An immigration judge ordered his removal, and the Board of Immigration Appeals dismissed his appeal. Meza-Carmona then petitioned for review. The Ninth Circuit transferred the case to the District of Arizona to resolve factual disputes about his citizenship claim. The district court found that Meza-Carmona failed to prove his mother's continuous physical presence in the U.S. for one year before his birth.The United States Court of Appeals for the Ninth Circuit reviewed the district court's findings. The court held that 8 U.S.C. § 1409(c) requires a person claiming citizenship to show that their mother stayed in the U.S. for one year without leaving. The Ninth Circuit found that the district court did not clearly err in determining that Meza-Carmona failed to establish his mother's continuous presence. The evidence allowed for either inference—that Victoria stayed continuously in the U.S. or that she did not. Given the record, the district court's conclusion was not clear error. Consequently, the Ninth Circuit denied Meza-Carmona's petition for review. View "MEZA-CARMONA V. GARLAND" on Justia Law

The plaintiffs, parents of Idaho school children, sought reimbursement for fees associated with educational and extracurricular activities within Idaho public school districts. They argued that these fees were improperly assessed because the Idaho Constitution mandates "free common schools," and that the payment of such fees constituted a taking of property without due process, violating the Takings Clause of the Fifth Amendment.The United States District Court for the District of Idaho initially denied the school districts' motion for summary judgment, concluding that the plaintiffs had a property interest in a free education under the Idaho Constitution. However, the case was later reassigned to a different district judge, who revisited the issue. The second district judge granted summary judgment in favor of the school districts, concluding that the plaintiffs did not possess a property right protected by the Takings Clause because the right to a free public education in Idaho does not constitute a vested private property interest.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the Idaho Constitution does not create a vested private property interest in specific educational benefits. It determined that public education in Idaho lacks the essential characteristics of private property, such as the right to possess, use, dispose of, or sell. Therefore, money paid to satisfy fees related to supplemental educational services is not subject to a Takings Clause claim. The court also clarified that a second district judge should not reconsider a prior judge's ruling unless specific conditions are met, but found any procedural error in this case to be harmless. View "Zeyen v. Bonneville Joint District" on Justia Law

The case involves EPD Investment Co., LLC (EPD) and its owner, Jerrold S. Pressman, who were found to have operated a Ponzi scheme. EPD was forced into Chapter 7 bankruptcy by its creditors, and the Trustee, Jason M. Rund, filed an adversary proceeding against Poshow Ann Kirkland and her husband, John Kirkland, seeking to avoid fraudulent transfers made by EPD to John. John had assigned his interest in EPD to the Bright Conscience Trust, for which Ann is the trustee.The United States District Court for the Central District of California bifurcated the trial, separating the claims against John and Ann. A jury trial was conducted for the claims against John, resulting in a verdict that EPD was a Ponzi scheme but that John received payments in good faith and for reasonably equivalent value. The bankruptcy court ruled that the jury's findings would be binding in the Trustee's claims against Ann. Ann appealed the judgment, particularly challenging the jury's finding that EPD was a Ponzi scheme.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Ann had standing to appeal due to her significant involvement in the case and her interest in the issues presented. The court rejected Ann's argument that the district court erred by not including a mens rea instruction requiring the jury to find that Pressman knew he was operating a Ponzi scheme that would eventually collapse. The court held that fraudulent intent could be inferred from the existence of a Ponzi scheme established through objective criteria. The court also rejected Ann's argument that the district court erred by instructing the jury that lenders are investors for purposes of a Ponzi scheme.The Ninth Circuit affirmed the district court's order affirming the judgment of the bankruptcy court and remanded the case for further proceedings. View "In re: EPD INVESTMENT COMPANY V. KIRKLAND" on Justia Law

C.R. Bard, Inc. (Bard), a medical device company, held patents on a vascular graft and entered into a licensing agreement with Atrium Medical Corporation (Atrium) to settle a patent infringement lawsuit. The agreement required Atrium to pay Bard a 15% per-unit royalty on U.S. sales until the U.S. patent expired in 2019 and on Canadian sales until the Canadian patent expired in 2024. Additionally, Atrium was to pay a minimum royalty of $3.75 million per quarter until the FDA approved the iCast stent for vascular use or rescinded its approval for all uses. Atrium ceased minimum royalty payments after the U.S. patent expired, leading Bard to sue for breach of contract.The United States District Court for the District of Arizona held a bench trial and found that the minimum royalty provision was primarily intended to compensate Bard for U.S. sales, thus constituting patent misuse under Brulotte v. Thys Co. The court concluded that the provision violated Brulotte because it effectively extended royalties beyond the patent's expiration based on the parties' motivations during negotiations.The United States Court of Appeals for the Ninth Circuit reversed the district court's judgment. The appellate court clarified that the Brulotte rule requires examining whether a contract explicitly provides for royalties on the use of a patented invention after the patent's expiration. The court held that the licensing agreement did not violate Brulotte because it provided for U.S. royalties only until the U.S. patent expired and Canadian royalties until the Canadian patent expired. The minimum royalty payments were not tied to post-expiration use of the U.S. patent but were instead based on Canadian sales, which continued to be valid under the Canadian patent. The Ninth Circuit concluded that the district court erred by considering the parties' subjective motivations and reversed the judgment for Atrium on Bard’s breach of contract claim. View "C.R. BARD, INC. V. ATRIUM MEDICAL CORPORATION" on Justia Law

Plaintiffs, dog owners, alleged that Nutramax Laboratories falsely marketed their product, Cosequin, as promoting healthy joints in dogs, despite evidence suggesting it provided no such benefits. They claimed this violated the California Consumers Legal Remedies Act (CLRA). The district court certified a class of California purchasers who were exposed to the allegedly misleading statements on Cosequin’s packaging.The United States District Court for the Central District of California certified the class, relying on the proposed damages model of Plaintiffs’ expert, Dr. Jean-Pierre Dubé, who had not yet executed his model. Nutramax challenged this, arguing that the model needed to be applied to the class to demonstrate that damages were susceptible to common proof. The district court found Dr. Dubé’s model sufficiently reliable for class certification purposes and concluded that common questions predominated regarding injury. Nutramax also contended that the element of reliance was not susceptible to common proof, but the district court found that classwide reliance could be established through proof of material misrepresentation.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that there is no general requirement for an expert to apply a reliable damages model to the proposed class to demonstrate that damages are susceptible to common proof at the class certification stage. The court concluded that the district court did not abuse its discretion in finding Dr. Dubé’s proposed model sufficiently sound. Additionally, the court rejected Nutramax’s argument regarding reliance, affirming that classwide reliance could be established under the CLRA through proof of material misrepresentation. The Ninth Circuit affirmed the district court’s grant of class certification. View "LYTLE V. NUTRAMAX LABORATORIES, INC." on Justia Law