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

A national trade association representing large online businesses challenged a recently enacted California statute designed to protect minors’ privacy and well-being online. The law imposes specific requirements on businesses whose online services are likely to be accessed by children under eighteen, including obligations regarding data use, age estimation, and restrictions on certain user interface designs known as “dark patterns.” Before the law took effect, the association brought suit in the United States District Court for the Northern District of California, arguing that several provisions were unconstitutional on First Amendment and vagueness grounds, and sought a preliminary injunction to prevent enforcement.The district court initially enjoined the entire statute, finding the association was likely to succeed on its facial First Amendment challenge. On the State’s appeal, the United States Court of Appeals for the Ninth Circuit vacated most of the injunction, affirming only as to a specific requirement regarding Data Protection Impact Assessments and related inseverable provisions, and remanded for the district court to analyze the association’s other facial challenges and the issue of severability under the Supreme Court’s clarified standards in Moody v. NetChoice, LLC. On remand, the district court again enjoined the entire statute and, in the alternative, seven specific provisions.On further appeal, the United States Court of Appeals for the Ninth Circuit held that the association did not meet its burden for a facial challenge to the law’s coverage definition or its age estimation requirement, vacating the injunction as to those. However, the court affirmed the preliminary injunction as to the law’s data use and dark patterns restrictions on vagueness grounds, finding the provisions failed to clearly delineate prohibited conduct. The court vacated the injunction as to the statute’s remainder and remanded for further proceedings on severability. View "NETCHOICE, LLC V. BONTA" on Justia Law

The case concerns a habeas corpus petition filed by an individual convicted and sentenced to death for the willful, deliberate, and premeditated murder of Janine Lee in California in 1993. The petitioner had worked with the victim and, after planning the crime, killed her for financial gain and subsequently attempted to cash her checks. Forensic evidence and the petitioner’s confession corroborated his involvement, including details about the killing, use of martial arts training, and subsequent events. Expert testimony at trial highlighted the petitioner’s mental health issues, drug use, and troubled social history, but the jury found him guilty and sentenced him to death.Following his conviction and sentencing, the California Supreme Court affirmed the judgment on direct appeal and summarily denied habeas relief. The United States District Court for the Central District of California denied the federal habeas petition under 28 U.S.C. § 2254, but granted a certificate of appealability for claims of ineffective assistance of counsel during the penalty phase. The petitioner sought to expand the certificate to include additional claims related to competency and juror bias.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of habeas relief. Applying AEDPA deference, the Ninth Circuit held that the California Supreme Court could have reasonably determined that the petitioner failed to make a prima facie case for relief on all penalty-phase ineffective assistance subclaims, including alleged failures to investigate, prepare witnesses, and rebut aggravating evidence. The court also rejected cumulative error and competency claims, and denied a certificate of appealability for juror bias. The panel granted a certificate for one penalty-phase competency subclaim but affirmed its denial. The district court’s denial of habeas corpus relief was affirmed. View "COMBS V. BROOMFIELD" on Justia Law

Two blind individuals, after enrolling at a community college in Los Angeles, were approved for disability accommodations, including accessible course materials and technology. Despite these approvals, they faced repeated barriers in accessing required textbooks, online platforms, library resources, and other educational tools. They also experienced difficulties in receiving their approved accommodations, such as accessible test-taking and note-taking support. These obstacles led to their inability to participate fully in their courses and, in one case, being steered away from certain classes due to their disability.After a jury trial in the United States District Court for the Central District of California, the jury found the college district liable on multiple counts and awarded damages for intentional violations of Title II of the Americans with Disabilities Act (ADA). The district court, however, reduced the damages to only out-of-pocket expenses, concluding that the jury’s award could only be for emotional distress or lost educational opportunities—both of which it believed were not recoverable. The district court also issued injunctive relief. The plaintiffs appealed the reduction of damages.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that, under Supreme Court precedent, emotional distress damages are not available under Title II of the ADA because the statute’s remedies are coextensive with those of the Rehabilitation Act and Title VI of the Civil Rights Act, which do not permit such damages. However, the Ninth Circuit concluded that plaintiffs may recover compensatory damages for loss of educational opportunities resulting from ADA violations. The court found that the jury’s award was supported by evidence and the instructions given. The Ninth Circuit reversed the district court’s remittitur, vacated its judgment as to damages, and remanded with instructions to reinstate the original jury awards. View "PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT" on Justia Law

Federal agents investigated a fatal fentanyl overdose in Goleta, California, and traced the source to Isaac Tekola. They discovered that Tekola had been selling drugs for years, primarily from his apartment. A search of his apartment revealed significant quantities of fentanyl, cocaine, methamphetamine, and Alprazolam, along with nearly $13,000 in cash, drug paraphernalia, and evidence that drug sales occurred at his residence. Tekola admitted that the cash came from drug dealing, and that a safe in his closet was used to store drugs and proceeds. His cell phone contained numerous messages confirming that his apartment was the hub of his trafficking operation.A grand jury indicted Tekola on several counts of possession with intent to distribute controlled substances under 21 U.S.C. § 841. He pled guilty to all charges without a plea agreement. At sentencing, the United States District Court for the Central District of California applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a premises for the purpose of manufacturing or distributing controlled substances. Tekola argued that, because his apartment was his primary residence, drug trafficking was not a primary or principal use of the premises. The district court found overwhelming evidence that the apartment was used as the central location for his drug business and imposed an above-Guidelines sentence of 105 months.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s application of the Sentencing Guidelines for abuse of discretion. The court held that the district court did not abuse its discretion in applying the § 2D1.1(b)(12) enhancement. The Ninth Circuit clarified that maintaining a primary residence as a central hub for substantial drug trafficking activity qualifies for the enhancement, even if the premises also serve as a residence, affirming Tekola’s sentence. View "USA V. TEKOLA" on Justia Law

A noncitizen applied to the United States Citizenship and Immigration Services (USCIS) for a U visa, which is available to victims of certain crimes who assist law enforcement. However, he acknowledged being inadmissible to the United States due to prior unlawful entries and removals, and sought a waiver of inadmissibility, which is granted at the discretion of the Secretary of Homeland Security if considered to be in the public or national interest. USCIS denied both his waiver request and his U visa application. He appealed the denials within the agency, but the Administrative Appeals Office dismissed the appeal. After the agency reopened and reconsidered his applications, it again denied both.The plaintiff then filed a suit in the United States District Court for the District of Idaho under the Administrative Procedure Act (APA), challenging the denial of his waiver and U visa. He later amended his complaint to add a claim that USCIS violated his Fifth Amendment right to due process by exhibiting bias. The defendants moved to dismiss for lack of subject matter jurisdiction. The district court granted the motion, holding that the Immigration and Nationality Act (INA) precludes judicial review in district courts of discretionary waiver decisions under 8 U.S.C. § 1182(d)(14).On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s jurisdictional determination de novo. The Ninth Circuit affirmed the dismissal, holding that the agency’s denial of a waiver is within the discretionary authority specified in the INA and thus falls under 8 U.S.C. § 1252(a)(2)(B)(ii), which strips district court jurisdiction. The court clarified that the savings clause in § 1252(a)(2)(D) applies only to petitions for review of final orders of removal in courts of appeals, not to APA suits in district court. The court also found no colorable constitutional claim challenging agency procedures and thus lacked jurisdiction over that claim as well. View "CHAIREZ V. MAYORKAS" on Justia Law

The President issued an executive order in January 2025 suspending the entry of all refugees into the United States under the United States Refugee Admissions Program (USRAP), citing concerns about national capacity and security. The Department of State, in response, suspended and later terminated funding for both overseas and domestic refugee resettlement services, including cooperative agreements with resettlement organizations. Plaintiffs, consisting of affected refugees and resettlement agencies, challenged these actions, arguing that the suspension exceeded the President’s statutory authority and that the funding terminations violated the Administrative Procedure Act (APA) and the Refugee Act.Upon review, the United States District Court for the Western District of Washington granted two preliminary injunctions. The first prohibited enforcement of the executive order suspending refugee admissions and related funding, and the second required the reinstatement of terminated cooperative agreements with resettlement agencies. The Government immediately appealed and sought stays of these injunctions. The district court also certified three plaintiff classes and further clarified the scope of its injunctions.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the President acted within his statutory authority under 8 U.S.C. § 1182(f) in suspending refugee admissions and in pausing decisions on refugee applications, and it reversed the district court’s injunctions to the extent they blocked these actions. The court also concluded that suspending overseas refugee processing and related funding did not violate the Refugee Act or the APA. However, the court affirmed the injunction as to the termination of domestic resettlement services, holding that the Government was likely acting contrary to law and arbitrarily and capriciously by failing to provide statutorily mandated resettlement services to admitted refugees. The scope of the injunction was upheld as compliant with recent Supreme Court precedent. View "PACITO V. TRUMP" on Justia Law

Two companies that operate app-based delivery platforms challenged a Seattle ordinance enacted in 2023, which aims to protect gig economy workers from unwarranted account deactivations. The law requires “network companies” to provide workers with written deactivation policies and mandates that these policies be “reasonably related” to the companies’ safe and efficient operations. The ordinance also delineates examples of impermissible deactivation grounds, such as those based solely on customer ratings or certain background checks. The companies did not contest the general bar on unwarranted deactivations but argued that the notice and deactivation policy requirements violate the First Amendment and that the ordinance is unconstitutionally vague.In the United States District Court for the Western District of Washington, the companies sought a preliminary injunction to prevent the ordinance from taking effect. The district court denied their motion. It found that the ordinance regulates conduct (the act of deactivating accounts) rather than speech, and that any impact on expression is incidental. The court also concluded that the use of “reasonable” in the ordinance was not unconstitutionally vague, pointing to statutory context and specific examples for guidance.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of injunctive relief. The court held that the ordinance regulates nonexpressive conduct, not speech, and thus does not trigger First Amendment scrutiny. Alternatively, if the ordinance were seen as regulating speech, that speech would be commercial in nature, and the law would satisfy the lower level of scrutiny applicable to compelled factual commercial disclosures. The court further held that the ordinance is not unconstitutionally vague, as it provides adequate notice of what is prohibited. The disposition by the Ninth Circuit was to affirm the district court’s denial of injunctive relief. View "MAPLEBEAR INC. V. CITY OF SEATTLE" on Justia Law

Richard and Lucia Parks, along with their family real estate business Parks Diversified, L.P. and related entities, became involved in a legal dispute after their son, David Klein, filed a voluntary Chapter 11 bankruptcy petition on behalf of Parks Diversified. The Parkses asserted that Klein did not have the authority to file the petition and claimed he did so as part of a scheme to take control of family assets. Despite these objections, the parties entered into a stipulation to dismiss the bankruptcy case, with the Parkses waiving certain claims. Later, the Parkses and their entities filed a complaint in California state court against Klein and others, alleging various causes of action related to the alleged unauthorized bankruptcy filing.Following this, the law firm representing some of the defendants requested the bankruptcy court to reopen the case, and the state court complaint was removed to the bankruptcy court. The bankruptcy court dismissed the claims for failure to state a claim and granted special motions to strike. On appeal, the United States District Court for the Central District of California found that the bankruptcy court had subject-matter jurisdiction over the case, holding that the issue of corporate authority to file a bankruptcy petition was not jurisdictional. The district court remanded with instructions to vacate orders where jurisdiction was lacking and to remand remaining claims to state court.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that, consistent with precedents from the Second and Third Circuits, a lack of corporate authority to file a bankruptcy petition does not deprive the bankruptcy court of subject-matter jurisdiction. The court clarified that while proper authorization is mandatory, it is not jurisdictional, and thus affirmed the lower court’s conclusion on this point. View "TALON DIVERSIFIED HOLDINGS INC. V. BECKER" on Justia Law

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation.The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty.On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law

The case concerns a challenge brought by an environmental non-profit against the U.S. Environmental Protection Agency (EPA) relating to the agency’s 2016 national recommendations for allowable cadmium levels in water. The EPA, as required by the Clean Water Act (CWA), periodically issues nonbinding criteria for water pollutants, which states typically adopt as standards for their own waters. In 2016, the EPA updated its cadmium recommendations but did so without consulting the Fish and Wildlife Service or the National Marine Fisheries Service, as mandated under Section 7 of the Endangered Species Act (ESA) for actions that may affect protected species.Previously, the United States District Court for the District of Arizona found that the Center for Biological Diversity (CBD) had standing to challenge the EPA’s failure to consult. The district court granted summary judgment in favor of CBD, holding that the EPA’s issuance of the cadmium recommendations constituted “agency action” under the ESA that “may affect” listed species, thus triggering the consultation requirement. The court vacated the less stringent chronic freshwater cadmium recommendation and remanded all four 2016 cadmium recommendations to the EPA for proper consultation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that CBD had Article III standing, finding a concrete injury to its members’ interests in protected species, that the injury was fairly traceable to EPA’s recommendations due to predictable state adoption, and that the injury could be redressed by stricter recommendations resulting from consultation. On the merits, the court concluded that EPA’s publication of nationwide recommendations was “agency action” under the ESA and that such action “may affect” listed species, thus requiring prior consultation with the Services. The district court’s vacatur and remand were affirmed. View "CENTER FOR BIOLOGICAL DIVERSITY V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY" on Justia Law