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

The case involves Katie Garding, who was convicted by a Montana jury of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver’s license. Garding filed a habeas petition, arguing that her counsel was ineffective for not hiring an accident reconstruction expert and that the prosecution violated her rights by not disclosing certain evidence.The Montana Supreme Court rejected Garding's arguments. It held that her counsel's decision not to hire an accident reconstruction expert was within the wide range of professionally competent assistance. The court also found that the state had not suppressed evidence concerning x-rays of the victim and that Garding did not show that the non-disclosure of photos from a different car crash was material.Garding then sought federal habeas relief. The United States District Court for the District of Montana partially granted and partially denied her petition. It held that there was ineffective assistance of counsel but denied the Brady claims.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s order denying Garding’s Brady claims and reversed its grant of Garding’s ineffective-assistance-of-counsel claim. The court held that the Montana Supreme Court reasonably determined that Garding’s trial counsel was not constitutionally deficient and that her Brady claims lacked merit. View "Garding v. Montana Department of Corrections" on Justia Law

The case involves Vladimir Hernandez, who pleaded guilty to felony meth distribution charges. As part of his plea, Hernandez agreed to provide the government with all the information he knew about the crime in exchange for a potential lower sentence under the safety-valve sentencing provision. However, after entering his plea, Hernandez learned that other inmates might retaliate against him for his cooperation with the government. He then sought to withdraw his guilty plea, arguing that he would not have agreed to the plea deal if he had known about the potential danger in prison.The district court denied Hernandez's motion to withdraw his plea. The court accepted that Hernandez did not know about the potential danger at the time of his plea and that his request to withdraw was made in good faith. However, the court concluded that Hernandez could avoid the consequences of the safety-valve proffer by not proffering, and thus his concerns were not "fair and just" reasons for withdrawal.The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case. The appellate court held that a defendant must first offer in good faith a "new" basis for seeking to withdraw his plea, meaning that he subjectively did not know this "new" reason for withdrawal at the time of his plea. He then must show that objectively he could not have known or anticipated this "new" material reason. The appellate court found that the district court did not err in concluding that Hernandez offered in good faith a subjectively new basis for withdrawing his plea. However, the district court did not decide whether objectively Hernandez could have known about or anticipated this new and material reason for withdrawing the plea. The appellate court remanded the case for the district court to decide that issue. View "United States v. Hernandez" on Justia Law

Tomas Perez, an underground haul truck driver, sued his former employer, Barrick Goldstrike Mines, Inc., alleging that the company wrongfully interfered with his rights under the Family and Medical Leave Act (FMLA) when it terminated his employment. Perez claimed that he had suffered a serious health condition that prevented him from performing his job, and that Barrick terminated his employment because he sought protected leave. Barrick, however, argued that Perez had faked his injury and violated company policy.The case was first heard in the United States District Court for the District of Nevada. The jury found in favor of Barrick, concluding that Perez failed to show by a preponderance of the evidence that he suffered a serious health condition preventing him from performing his job or that Barrick terminated his employment because he sought protected leave. Perez appealed the decision, arguing that the district court erred by not instructing the jury that only contrary medical evidence could defeat his doctor’s certification of a serious health condition.The case was then reviewed by the United States Court of Appeals for the Ninth Circuit. The court held that the FMLA does not require an employer to present contrary medical evidence before contesting a doctor’s certification of a serious health condition. Therefore, the district court did not err by failing to instruct the jury that only contrary medical evidence could defeat Perez’s doctor’s certification. The jury was allowed to properly consider the non-medical evidence that Barrick offered at trial in support of its argument that Perez did not have a serious health condition within the meaning of the Act. The court affirmed the district court’s judgment in favor of Barrick. View "Perez v. Barrick Goldstrike Mines, Inc." on Justia Law

The case involves Gillian and Samuel Davidson, who filed a class action lawsuit against Sprout Foods, Inc., alleging that the labels on Sprout's baby food pouches violated California's Sherman Law, which incorporates all federal food labeling standards. The Davidsons claimed that Sprout's labels, which stated the amount of nutrients the pouches contained, were misleading and harmful to consumers.The district court dismissed the Davidsons' claims. It ruled that the Sherman Law claim was preempted by federal law, which only allows the federal government to enforce food labeling standards. The court also dismissed the Davidsons' fraud-based claims, stating that they failed to specifically allege why Sprout's products were harmful.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that federal law did not preempt private enforcement of the Sherman Law's labeling requirements. The court reasoned that the federal food labeling statute permits states to enact labeling standards identical to the federal standards, which California has done through the Sherman Law. Therefore, the district court should not have dismissed the Sherman Law claims. However, the court affirmed the dismissal of the Davidsons' fraud-based claims, agreeing with the lower court that the Davidsons failed to meet the heightened pleading requirements for fraud. The court also reversed the dismissal of an unjust enrichment claim, which survived due to the reversal on the Sherman Law claim. View "Davidson v. Sprout Foods, Inc." on Justia Law

The case involves Gilberto Azael Leon Perez, a Mexican national and legal permanent resident of the United States, who was convicted of attempted lewdness with a child under the age of 14, in violation of Nevada law. Following his conviction, the Department of Homeland Security charged Perez as removable based on his conviction, which they argued constituted an "aggravated felony" under the Immigration and Nationality Act (INA). An immigration judge agreed, finding that the conviction was for an attempted aggravated felony that rendered Perez removable from the United States. Perez appealed to the Board of Immigration Appeals (BIA), which dismissed the appeal, thus affirming the immigration judge's removal order.The United States Court of Appeals for the Ninth Circuit was tasked with reviewing the case. The court had to decide whether their precedent, which sets out the generic definition of sexual abuse of a minor, was clearly irreconcilable with a Supreme Court decision, Esquivel-Quintana v. Sessions. The court held that it was not. The court also held that the BIA did not err in concluding that Perez’s conviction categorically constituted an attempted “sexual abuse of a minor” aggravated felony that renders him removable. Therefore, the court denied Perez's petition for review. View "PEREZ V. GARLAND" on Justia Law

The case involves Angelo Corey Stackhouse, who was convicted of kidnapping a minor and transporting a person across state lines with the intent to engage in illegal sexual activity. Stackhouse kidnapped a 10-year-old girl, using a cellphone during the crime, and transported a 19-year-old woman from Montana to Denver, where he sexually assaulted her.Previously, the United States District Court for the District of Montana convicted Stackhouse on all seven charges. He appealed his convictions for kidnapping a person under the age of 18 using a means or instrumentality of interstate commerce, and for the transportation of a person across state lines with intent to engage in illegal sexual activity.The United States Court of Appeals for the Ninth Circuit affirmed Stackhouse’s convictions. The court held that the application of the federal kidnapping statute to an intrastate kidnapping is constitutional where the defendant uses a cellphone—an instrumentality of interstate commerce—in furtherance of the offense. The court also held that the government presented sufficient evidence of Stackhouse’s intent to commit sexual assault when he transported the victim of his assault across state lines. The court concluded that the application of the federal kidnapping statute to an intrastate kidnapping is constitutional where the defendant uses a cellphone in furtherance of the offense, and that Stackhouse’s actions leading up to and during the trip to Denver established that he had the intent to commit illegal sexual activity when he transported the victim interstate. View "USA V. STACKHOUSE" on Justia Law

The plaintiff, Purushothaman Rajaram, a naturalized U.S. citizen, alleged that Meta Platforms, Inc., refused to hire him because it preferred to hire noncitizens holding H1B visas, to whom it could pay lower wages. Rajaram claimed that this constituted employment discrimination under 42 U.S.C. § 1981, which prohibits discrimination in hiring against U.S. citizens based on their citizenship.The district court dismissed Rajaram's complaint, ruling that section 1981 does not prohibit discrimination based on U.S. citizenship. Rajaram appealed this decision to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit disagreed with the district court's interpretation of section 1981. The appellate court held that the statutory text of section 1981 prohibits employers from discriminating against U.S. citizens. The court reasoned that an employer that discriminates against U.S. citizens gives one class of people—noncitizens—a greater right to make contracts than U.S. citizens. This interpretation, the court held, is consistent with the plain language of the statute, which guarantees that all persons shall have the same right to make and enforce contracts as is enjoyed by white citizens.The Ninth Circuit reversed the district court's dismissal of Rajaram's employment discrimination action and remanded the case for further proceedings. The court concluded that section 1981 does prohibit discrimination in hiring against U.S. citizens on the basis of their citizenship. View "RAJARAM V. META PLATFORMS, INC." on Justia Law

Several environmental organizations filed a citizen suit against private timber companies under the Endangered Species Act (ESA), alleging that the companies' planned logging project in Oregon would harm marbled murrelets, a species of threatened birds. The district court agreed with the plaintiffs and issued a permanent injunction against the logging project. The timber companies appealed, arguing that the court lacked jurisdiction because the plaintiffs' notice of the suit was invalid.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that the ESA's citizen-suit notice requirement is not jurisdictional, but a claims-processing rule subject to waiver and forfeiture. The court found that the timber companies possibly forfeited their challenge to the notice letter, but decided to address the issue and concluded that the notice was sufficient.The court also held that the district court correctly applied the standard for "actual injury" under the ESA. The court found that the timber companies' planned actions would "harm" marbled murrelets, as the logging project would significantly impair the birds' breeding patterns by removing their habitat. The court concluded that the plaintiffs had established proximate causation under the ESA, and thus, the permanent injunction against the logging project was upheld. View "Cascadia Wildlands v. Scott Timber Co." on Justia Law

The case revolves around a clerical error by the Internal Revenue Service (IRS) that resulted in a taxpayer, Jeffrey Page, receiving a tax refund check significantly larger than he was entitled to. Page returned only a portion of the excess refund, prompting the United States government to sue under 26 U.S.C. § 7405 to recover the outstanding balance. Page did not respond to the lawsuit, leading the government to move for default judgment. However, the district court denied the motion and dismissed the complaint as untimely, arguing that the two-year limitations period began when Page received the refund check.The United States Court of Appeals for the Ninth Circuit disagreed with the district court's interpretation of when the two-year limitations period began. The appellate court held that the limitations period to sue to recover an erroneous refund starts on the date the erroneous refund check clears the Federal Reserve and payment to the taxpayer is authorized by the Treasury. As Page's refund check cleared less than two years before the government sued, the appellate court held that the complaint was timely and that the district court erred by dismissing it. The appellate court also noted that the district court had improperly shifted the burden to the government to prove at the pleading stage that its claim against Page was timely. The case was reversed and remanded for further proceedings. View "United States v. Page" on Justia Law

Christopher Grimes, a California state inmate, was convicted of second-degree murder. The conviction was based, in part, on statements Grimes made to an undercover jailhouse informant after he had invoked his Fifth Amendment right to counsel. Grimes appealed his conviction, arguing that his statements to the informant should have been suppressed because they were obtained in violation of his right to counsel.The California Court of Appeal affirmed Grimes' conviction. It held that the statements were admissible because law enforcement is not required to give Miranda warnings to a suspect before placing them in a jail cell with an undercover informant. This decision was based on the U.S. Supreme Court case Illinois v. Perkins, which held that the policy underlying Miranda is not implicated when a suspect makes statements to an individual they believe is a fellow inmate. Grimes' petition for review before the California Supreme Court was denied without comment.Grimes then filed a federal habeas petition, arguing that the California Court of Appeal misapplied Edwards v. Arizona, which held that law enforcement must cease custodial interrogation when a suspect invokes their right to counsel unless they subsequently waive that right. The United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of Grimes' habeas petition. The court held that because the Supreme Court has never squarely addressed whether the Fifth Amendment precludes an undercover jailhouse informant posing as an inmate to question an incarcerated suspect who has previously invoked his right to counsel, the California Court of Appeal’s decision is not contrary to, or an unreasonable application of, clearly established federal law as defined by the Antiterrorism and Effective Death Penalty Act of 1996. View "Grimes v. Phillips" on Justia Law