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

The case involves a challenge to Arizona's voter registration law, specifically A.R.S. § 16-121.01(C), which requires documentary proof of citizenship (DPOC) for voter registration. Plaintiffs, including various advocacy groups and individuals, argued that this law conflicts with a prior consent decree (LULAC Consent Decree) that allows voter registration without DPOC for federal elections. The district court issued an injunction barring the enforcement of the law, leading to an appeal by the Intervenors-Defendants-Appellants, including the Republican National Committee and Arizona state legislators.The United States District Court for the District of Arizona ruled in favor of the plaintiffs, finding that the new law violated the LULAC Consent Decree. The court issued an injunction preventing the enforcement of A.R.S. § 16-121.01(C). The Intervenors-Defendants-Appellants filed an emergency motion to stay the district court's judgment, which was partially granted by a motions panel of the Ninth Circuit Court of Appeals. The motions panel stayed the injunction concerning A.R.S. § 16-121.01(C) but left the rest of the district court's judgment intact.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court granted the plaintiffs' emergency motion for reconsideration of the partial stay. The Ninth Circuit vacated the motions panel's order that had stayed the district court's injunction against enforcing A.R.S. § 16-121.01(C). The court found that the Intervenors-Defendants-Appellants did not demonstrate a strong likelihood of success on the merits or a high degree of irreparable injury. The court emphasized the importance of maintaining the status quo in election cases to avoid voter confusion and potential disenfranchisement, citing the Supreme Court's decision in Purcell v. Gonzalez. The court concluded that the balance of hardships and public interest favored vacating the stay. View "MI FAMILIA VOTA, V. MAYES" on Justia Law

Five corporate jet pilots worked for Sands Aviation, LLC and Las Vegas Sands Corp., earning between $125,000 and $160,000 annually. Their primary duties included ensuring the safety of passengers, crew, and aircraft, which involved complex decision-making and discretionary actions. The pilots were required to be on call for pop-up flights, typically scheduled 24 hours in advance, and had to respond to flight notifications within 30 minutes. Despite being on call, they engaged in various personal activities and secondary employment.The United States District Court for the District of Nevada held a bench trial and ruled in favor of Sands. The court found that the pilots were highly compensated employees performing primarily non-manual labor and making significant discretionary decisions, thus exempting them from the Fair Labor Standards Act (FLSA) overtime requirements. Additionally, the court determined that the pilots' on-call time did not constitute work requiring overtime pay because they could freely engage in personal activities during this time.The United States Court of Appeals for the Ninth Circuit affirmed the district court's judgment. The appellate court agreed that the pilots were exempt from the FLSA's overtime requirements as highly compensated employees performing non-manual labor and making significant discretionary decisions. The court also held that the pilots' on-call time did not count as work for overtime purposes, as they were free to engage in personal activities and there was no agreement suggesting that on-call time was compensable. Thus, the pilots did not meet the 40-hour workweek threshold for overtime pay. View "KENNEDY V. LAS VEGAS SANDS CORPORATION" on Justia Law

The plaintiffs, Cambodian villagers, alleged they were victims of human trafficking while working at seafood processing factories in Thailand. They claimed the factories, owned by Thai corporations Phatthana Seafood Co., Ltd. and S.S. Frozen Food Co., Ltd., subjected them to abusive conditions. Rubicon Resources, LLC, a U.S. company, was accused of knowingly benefiting from these violations by attempting to sell shrimp processed at these factories.The United States District Court for the Central District of California granted summary judgment in favor of Rubicon, holding that the plaintiffs failed to provide evidence that Rubicon knowingly benefited from the trafficking venture. The court also found no evidence that Rubicon knew or should have known about the violations. The plaintiffs appealed, and the Ninth Circuit affirmed the district court's decision, interpreting the statute to exclude liability for attempts to benefit from trafficking violations.Subsequently, Congress amended the Trafficking Victims Protection Reauthorization Act (TVPRA) through the Abolish Trafficking Reauthorization Act (ATRA), which expanded liability to include those who "attempt or conspire to benefit" from trafficking violations. The plaintiffs filed a motion under Rule 60(b)(6) to reopen the judgment based on this legislative change, arguing that the amendment clarified the original intent of the TVPRA.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b)(6) motion. The Ninth Circuit held that ATRA did not apply retroactively to events that occurred before its enactment. The court reasoned that the lack of an express statutory command for retroactive application and the forward-looking nature of the amendment indicated that ATRA was not intended to clarify the original statute but to change it. Therefore, the district court did not err in declining to reopen the final judgment. View "RATHA V. RUBICON RESOURCES, LLC" on Justia Law

Roy Scott, who was unarmed and in mental distress, called the police for help. Officers Kyle Smith and Theodore Huntsman from the Las Vegas Metropolitan Police Department responded. Despite Scott complying with their orders and not being suspected of a crime, the officers used force to restrain him. Scott lost consciousness shortly after and was later pronounced dead. Scott’s daughter Rochelle and a representative of Scott’s estate sued the Department and the two officers, alleging violations of Scott’s Fourth Amendment right to be free from excessive force and Rochelle’s Fourteenth Amendment right to familial association.The United States District Court for the District of Nevada denied the officers' motion for summary judgment on the basis of qualified immunity for both the Fourth and Fourteenth Amendment claims. The officers appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on the Fourth Amendment claim, holding that the officers violated Scott’s Fourth Amendment right to be free from excessive force. The court found that Scott was mentally ill, not suspected of a crime, and did not present a risk to officers or others, making the use of severe or deadly force constitutionally excessive. The court also held that Scott’s Fourth Amendment rights were clearly established at the time of the violation, referencing Drummond ex rel. Drummond v. City of Anaheim.However, the Ninth Circuit reversed the district court’s denial of qualified immunity on Rochelle’s Fourteenth Amendment claim. The court held that while the officers violated Rochelle’s right to familial association, that right was not clearly established at the time of the officers’ conduct, entitling the officers to qualified immunity on this claim. The case was remanded for further proceedings consistent with the opinion. View "SCOTT V. SMITH" on Justia Law

The petitioner, a native and citizen of Mexico, entered the United States as a child and later obtained lawful permanent residency. He was convicted of petty theft and felony assault in California. Following these convictions, the Department of Homeland Security initiated removal proceedings against him. The petitioner sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT), citing a fear of future persecution and torture by his father, a member of the Los Zetas cartel, and other cartels in Mexico.The Immigration Judge (IJ) found the petitioner removable based on his theft and assault convictions. The IJ denied his applications for asylum and withholding of removal, determining that his assault conviction constituted a particularly serious crime, rendering him ineligible for withholding relief. The IJ also concluded that the petitioner had not established a well-founded fear of future persecution or that the Mexican government would be unwilling or unable to protect him. The IJ further denied CAT relief, finding insufficient evidence that the petitioner would more likely than not be tortured upon return to Mexico.The Board of Immigration Appeals (BIA) upheld the IJ's decision, agreeing that the assault conviction was a particularly serious crime and that the petitioner had not demonstrated eligibility for asylum or withholding of removal. The BIA also affirmed the denial of CAT relief, concluding that the petitioner had not shown a likelihood of future torture with the acquiescence of the Mexican government.The United States Court of Appeals for the Ninth Circuit reviewed the case and denied the petition for review. The court held that the BIA did not abuse its discretion in determining that the assault conviction was a particularly serious crime. The court also found that substantial evidence supported the BIA's conclusion that the petitioner had not demonstrated a likelihood of future torture in Mexico. The court emphasized that the evidence of past abuse in the United States did not compel a conclusion that the petitioner would be tortured in Mexico. View "G. C. V. GARLAND" on Justia Law

Plaintiff, a Bank of America (BOA) accountholder, was charged two separate out-of-network (OON) balance inquiry fees when using a non-BOA ATM. She claimed that only the first fee was permissible under the contract, arguing that a "balance inquiry" should be defined as a customer-initiated request for balance information. BOA contended that it could charge a fee whenever an ATM transmitted a balance inquiry request, regardless of the customer's actions.The United States District Court for the Southern District of California granted summary judgment in favor of BOA on both the breach of contract and breach of the implied covenant of good faith and fair dealing claims. The court also denied class certification, reasoning that individual issues predominated over common ones, particularly concerning the subjective intent of each class member and variations in ATM prompts.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment on the breach of contract claim, agreeing with the plaintiff that a "balance inquiry" should be defined as a customer-initiated transaction. The court found that BOA's interpretation, which allowed fees based on ATM transmittals, was unreasonable and not supported by the contract's language. The court affirmed the summary judgment on the implied covenant of good faith and fair dealing claim, as it was indistinguishable from the breach of contract claim. The court also affirmed the district court's decision that the plaintiff's failure to follow pre-dispute procedures did not bar her claim.The Ninth Circuit vacated the denial of class certification and remanded the case for reconsideration, noting that the court's interpretation of "balance inquiry" alleviated concerns about the need to probe the subjective intent of individual class members. View "Schertzer v. Bank of America, NA" on Justia Law

John Doe, a detained alien, filed a habeas corpus petition under 28 U.S.C. § 2241 in the Northern District of California, challenging his detention at the Golden State Annex (GSA) in the Eastern District of California. He named several federal officials, including the Attorney General and the Acting Director for the San Francisco ICE Field Office, as respondents. Doe sought release unless he was provided a bond hearing. The district court granted Doe’s petition, leading to his release after a bond hearing.The district court denied the respondents' motion to dismiss, which argued that the court lacked jurisdiction because Doe did not name his immediate custodian and filed the petition outside the district of confinement. The court held that the Northern District of California was an appropriate jurisdiction for petitions filed by aliens detained by the San Francisco ICE Field Office.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s decision. The Ninth Circuit held that the district court erred in exercising jurisdiction over Doe’s habeas petition. The court explained that under Rumsfeld v. Padilla, a core habeas petition challenging present physical confinement must name the immediate custodian, typically the warden, and be filed in the district of confinement. Doe’s petition was a core habeas petition because it sought release from detention. However, Doe failed to name the Facility Administrator of GSA as the respondent and filed the petition in the Northern District of California instead of the Eastern District of California, where he was confined. Consequently, the Ninth Circuit reversed the district court’s denial of the motion to dismiss and remanded with instructions to vacate the grant of Doe’s habeas petition. View "DOE V. GARLAND" on Justia Law

The plaintiffs, EB Holdings II, Inc. and QXH II, Inc., sought coverage from their insurers for legal fees and expenses incurred in defending against a lawsuit alleging fraudulent inducement in the purchase of notes backed by their long-term debt. The insurers denied coverage, claiming the plaintiffs made material misrepresentations in their insurance renewal application by failing to disclose significant long-term debt.The United States District Court for the District of Nevada granted summary judgment in favor of the insurers, concluding that Nevada law governed the affirmative defense of material misrepresentation. The court found that the plaintiffs had indeed made a material misrepresentation by not disclosing their long-term debt, thus barring coverage under the insurance policies.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's decision. The appellate court held that the district court erred in its choice-of-law analysis. The Ninth Circuit determined that Texas law, not Nevada law, should govern the affirmative defense of material misrepresentation. The court reasoned that the substantial relationship test set forth in the Restatement (Second) of Conflict of Laws § 188 pointed to Texas law, given that the underwriting process largely occurred through agents based in Texas and the plaintiffs were headquartered there.Applying Texas law, the Ninth Circuit found that there were material disputes of fact regarding the elements of the affirmative defense, including the plaintiffs' intent to deceive and whether the insurers provided timely notice of their refusal to be bound by the policy. Consequently, the court reversed the summary judgment and remanded the case to the district court for further proceedings. View "EB HOLDINGS II, INC. V. ILLINOIS NATIONAL INSURANCE COMPANY" on Justia Law

The case involves debtors who filed a Chapter 11 bankruptcy petition, claiming a homestead exemption for their residence. They listed the exemption as "100% of FMV" (fair market value) on their bankruptcy schedule. No party in interest objected to this exemption within the 30-day period following the creditors' meeting. Later, the case was converted to Chapter 7 after one of the debtors passed away and the remaining debtor failed to meet Chapter 11 obligations. The Chapter 7 trustee sought to sell the residence, arguing that the exemption should be limited to the statutory cap.The Bankruptcy Court for the Eastern District of Washington ruled that the homestead exemption was limited to the statutory cap of $45,950, with the remaining value of the home belonging to the bankruptcy estate. The debtor appealed, and the Bankruptcy Appellate Panel (BAP) reversed the bankruptcy court's decision. The BAP held that because no objection was made within the 30-day period, the debtor was entitled to the full fair market value of the home, not limited by the statutory cap.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court distinguished this case from Taylor v. Freeland & Kronz and Schwab v. Reilly, noting that the case began as a Chapter 11 bankruptcy, where the debtors owed fiduciary duties to their creditors. The court emphasized that within the 30-day objection period, the debtors made specific representations in their Chapter 11 documents indicating that they were not claiming an above-limit exemption and that creditors would be paid in full before any above-limit exemptions were allowed.The Ninth Circuit held that the initial failure to object did not mean the debtor could exempt more than the statutory limit. The court concluded that the homestead exemption was limited to the statutory cap, and the remaining proceeds from the sale of the home were part of the bankruptcy estate. The decision of the BAP was reversed, and the case was remanded for further proceedings consistent with this opinion. View "IN RE: MASINGALE" on Justia Law

A group of non-convicted individuals detained in Alameda County’s Santa Rita Jail filed a lawsuit against Aramark Correctional Services, LLC, Alameda County, and Sheriff Gregory J. Ahern. The plaintiffs claimed they were entitled to minimum wage and overtime pay under California’s Labor Code for work performed without pay for Aramark while detained. The defendants moved to dismiss these claims, arguing that the plaintiffs' compensation was governed by the California Penal Code, which allows counties to pay prisoners at rates below minimum wage.The United States District Court for the Northern District of California denied the defendants' motion to dismiss the minimum wage and overtime claims, holding that the California Penal Code did not preclude non-convicted detainees working for a private company from the protections of the Labor Code. The district court allowed the plaintiffs' claims to proceed, leading the defendants to file an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and certified a question to the California Supreme Court regarding whether non-convicted detainees working for a private company in county jails have a claim for minimum wages and overtime under the California Labor Code. The California Supreme Court responded that such detainees do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code. The court clarified that section 4019.3 of the California Penal Code applies broadly to all county inmates, including pretrial detainees, and does not depend on the identity of the employer.Based on the California Supreme Court's response, the Ninth Circuit reversed the district court's order denying the motion to dismiss the plaintiffs' minimum wage and overtime claims. The court held that the plaintiffs' claims failed under the current law and reversed the district court's decision. View "RUELAS V. COUNTY OF ALAMEDA" on Justia Law