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

The case involves M&T Farms, a California general partnership between two farmers, who purchased crop insurance under the Whole-Farm Revenue Protection Pilot Policy (the “WFRP Policy”) from Producers Agriculture Insurance Company (“ProAg”), an insurer approved and reinsured by the Federal Crop Insurance Corporation (FCIC). M&T Farms and a third farmer sell farm commodities through a storefront, B&T Farms, which owns their business name and goodwill and is also a California general partnership. M&T Farms filed a claim seeking the full policy amount, which ProAg denied. The FCIC concluded that the WFRP Policy does not allow a partner who files taxes on a fractional share of farming activity conducted by a partnership to be eligible for WFRP coverage for the fractional share of that farming activity.The United States District Court for the Northern District of California granted summary judgment in favor of the FCIC. M&T Farms challenged the FCIC’s decision that a partnership “holding the business name and good will of [others] (i.e., marketing and selling the commodities produced)” is engaged in “farming activity” under section 3(a)(4) of the WFRP Policy, and that therefore, any entity reporting a fractional share of the partnership’s activity on its tax returns is ineligible for WFRP Policy coverage.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that the WFRP Policy contained an ambiguity regarding the definition of “farming activity.” The FCIC’s conclusion that a partnership selling its partners’ products and holding their goodwill and business name was engaged in “farming activity” under section 3(a)(4) of the policy had a reasonable basis and was also reasonable as a matter of policy. Because the FCIC’s interpretation of “farming activity” in the WFRP Policy was reasonable, it survived APA arbitrary and capricious review. The court also held that the term “farming activity” in the WFRP policy was genuinely ambiguous, the FCIC’s conclusion had a reasonable basis, and the FCIC’s conclusion was entitled to controlling weight. View "M & T FARMS V. FEDERAL CROP INSURANCE CORPORATION" on Justia Law

A class of individuals and businesses in Northern California, who paid health insurance premiums to certain health plans, sued Sutter Health, a healthcare system operator in the region. They alleged that Sutter abused its market power to charge supracompetitive rates to these health plans, which were then passed on to the class in the form of higher premiums. The case went to trial on claims under California’s Cartwright Act for tying and unreasonable course of conduct. The jury returned a verdict in favor of Sutter.The plaintiffs appealed, arguing that the district court erred by failing to instruct the jury to consider Sutter’s anticompetitive purpose and by excluding evidence of Sutter’s conduct before 2006. The United States Court of Appeals for the Ninth Circuit agreed with the plaintiffs. It held that the district court contravened California law by removing “purpose” from the jury instructions, and that the legal error was not harmless. The court also held that the district court abused its discretion under Federal Rule of Evidence 403 in excluding as minimally relevant all evidence of Sutter’s conduct before 2006. The court concluded that these errors were prejudicial and reversed the district court’s judgment, remanding the case for a new trial. View "SIDIBE V. SUTTER HEALTH" on Justia Law

The case involves Marlon Alonzo Smith, a native and citizen of Guyana, who was found removable as an alien convicted of an aggravated felony. Smith challenged the authenticity and reliability of three documents the agency relied upon for its removability ruling: a Form I-213, Record of Deportable Alien; an FBI rap sheet; and a criminal judgment. He argued that these documents were not authenticated by any method and that an amendment to 8 C.F.R. § 287.6(a) made mandatory a requirement that domestic official records be authenticated.The Board of Immigration Appeals (BIA) concluded that Smith had not preserved his challenge to the authenticity of three of the Government’s exhibits, and they sufficed to establish his removability. The BIA also rejected Smith’s due process arguments and concluded that substantial evidence supported the denial of relief under the Convention Against Torture (CAT).The United States Court of Appeals for the Ninth Circuit denied Smith's petition for review. The court found that Smith did not preserve his challenge to the authenticity of the documents, and they were sufficient to establish his removability. The court also rejected Smith's due process arguments and concluded that substantial evidence supported the denial of CAT protection. The court did not resolve the issue of whether the amendment to 8 C.F.R. § 287.6(a) made mandatory a requirement that domestic official records be authenticated, leaving that analysis for another day. View "SMITH V. GARLAND" on Justia Law

The case revolves around Elizabeth Carley, an inmate in the custody of the Nevada Department of Corrections (NDOC), who filed a suit against Dr. Romeo Aranas, the former Medical Director of NDOC. Carley alleged that Dr. Aranas was deliberately indifferent to her medical needs when he denied her request for certain Hepatitis C (HCV) treatment. The district court denied Dr. Aranas' motion for summary judgment, concluding that he was not entitled to qualified immunity at that time.Previously, the district court had concluded that there was a genuine dispute of material fact as to whether Dr. Aranas was deliberately indifferent to Carley's serious medical needs. However, it did not proceed to the second step of the qualified immunity inquiry, which was whether the violation was clearly established at the time of the violation.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Dr. Aranas was entitled to qualified immunity because no clearly established law rendered the HCV policies unconstitutional at the time of the alleged violation. The court concluded that no decision of the Supreme Court, this court, or a “consensus of courts” would have put Dr. Aranas on notice that the relevant inmate treatment prioritization schemes violated the Eighth Amendment during his time as the NDOC Medical Director. Therefore, the court reversed the district court’s order and remanded with instructions to grant summary judgment for Dr. Aranas. View "CARLEY V. ARANAS" on Justia Law

The case involves Gerardo Farias-Contreras, who pleaded guilty to conspiring to distribute methamphetamine and heroin. As part of the plea agreement, the government agreed to dismiss two other charges and not to recommend a sentence exceeding the low-end of the guideline range. Farias-Contreras argued for a six-level reduction in the base offense level, resulting in a guidelines range of 108–135 months, citing his many physical disabilities. The government, after reducing the base offense level by three levels, calculated a guidelines range of 151–188 months and recommended a 151-month term.The United States District Court for the Eastern District of Washington sentenced Farias-Contreras to 188 months' imprisonment, citing substantially the facts and argument presented by the government. Farias-Contreras appealed, arguing that the government implicitly breached its promise under the plea agreement not to recommend a sentence in excess of the low-end of the sentencing guidelines range when the government implicitly urged the district court to impose a harsher sentence.The United States Court of Appeals for the Ninth Circuit affirmed the sentence. The court found that the government's conduct crossed the line from permissible advocacy to an improper end-run of the plea agreement, thus implicitly breaching its promise not to recommend a sentence in excess of the low-end of the calculated guideline range. However, the court concluded that the error was not plain because the court's precedent does not make sufficiently clear to what extent the government may respond to a defendant’s request for a downward departure without implicitly breaching the plea agreement. The court took the opportunity to clarify its law on the subject. View "USA V. FARIAS-CONTRERAS" on Justia Law

A class of indigent criminal defendants in Oregon, who were incarcerated and awaiting trial without legal representation, filed a federal habeas corpus petition. They argued that the state's failure to provide them with counsel violated their Sixth Amendment rights. The district court issued a preliminary injunction requiring that counsel be provided within seven days of the initial appearance, and if this did not occur, the defendants must be released from custody subject to reasonable conditions imposed by Oregon Circuit Court judges.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the district court did not abuse its discretion in concluding that the petitioners were likely to succeed on the merits of their Sixth Amendment claim. The court reasoned that without counsel, the petitioners could not understand, prepare for, or progress to critical stages of their cases. The court also held that the district court did not abuse its discretion in concluding that the petitioners were suffering and would continue to suffer irreparable harm. The court found that the public has an interest in a functioning criminal justice system and the protection of fundamental rights. View "Betschart v. Washington County Circuit Court Judges" on Justia Law

The case involves Bristol SL Holdings, Inc., the successor-in-interest to Sure Haven, Inc., a defunct drug rehabilitation and mental health treatment center, and Cigna Health and Life Insurance Company and Cigna Behavioral Health, Inc. Bristol alleged that Sure Haven's calls to Cigna verifying out-of-network coverage and seeking authorization to provide health services created independent contractual obligations. Cigna, however, denied payment based on fee-forgiving, a practice prohibited by the health plans. Bristol brought state law claims for breach of contract and promissory estoppel against Cigna.The district court initially dismissed Bristol’s claims, but the Ninth Circuit Court of Appeals reversed the dismissal, holding that Bristol had derivative standing to sue for unpaid benefits as Sure Haven’s successor-in-interest. On remand, the district court granted Cigna’s motion for summary judgment, ruling that the Employee Retirement Income Security Act of 1974 (ERISA) preempted Bristol’s state law claims.On appeal, the Ninth Circuit Court of Appeals affirmed the district court's decision. The court held that Bristol’s state law claims were preempted by ERISA because they had both a “reference to” and an “impermissible connection with” the ERISA plans that Cigna administered. The court reasoned that Bristol’s claims were not independent of an ERISA plan because they concerned the denial of reimbursement to patients who were covered under such plans. The court also held that allowing liability on Bristol’s state law claims would interfere with nationally uniform plan administration, a central matter of plan administration. View "Bristol SL Holdings, Inc. v. Cigna Health and Life Insurance Co." on Justia Law

The plaintiff, Rhita Bercy, filed a hostile work environment claim against her employer, the City of Phoenix, alleging a single course of conduct that continued over a period of nearly two years. She filed her bankruptcy petition within that two-year period. The claim was based on conduct that occurred both before and after she filed her bankruptcy petition. The parties agreed that a claim based on conduct before the petition, and any damages resulting from that conduct, belonged to the bankruptcy estate. The question was whether Bercy could recover damages on that claim for alleged harm arising from discriminatory conduct that occurred after she filed for bankruptcy.The United States District Court for the District of Arizona granted the City's motion for summary judgment, holding that Bercy lacked standing to pursue her claim. The court reasoned that because Bercy could have brought her claim at the time of her bankruptcy petition, and any subsequent damages were sufficiently rooted in prebankruptcy incidents, the entire claim belonged to the bankruptcy estate under 11 U.S.C. § 541(a)(1).On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that Bercy's hostile work environment claim was sufficiently rooted in the prebankruptcy past and thus belonged to the bankruptcy estate. Therefore, only the bankruptcy trustee had standing to sue on the claim. The court clarified that the Bankruptcy Code provides a “fresh start” to the debtor at discharge, but not “a continuing license to violate the law.” View "Bercy v. City of Phoenix" on Justia Law

The case involved Chanel Wiley, who was convicted for conspiracy to distribute methamphetamine. During jury selection, Wiley's ankle monitor, which she was wearing as a condition of her pretrial release, started beeping. Wiley argued that this incident prejudiced her and warranted a new trial.The district court judge acknowledged hearing the alert but did not believe the jurors knew what the sound was. After the monitor beeped again, the judge ordered a recess and had the monitor removed outside the presence of the jury. Wiley was subsequently convicted of conspiracy to distribute methamphetamine and acquitted of distributing methamphetamine.On appeal, the United States Court of Appeals for the Ninth Circuit assumed that at least one juror concluded that the beeping sound meant Wiley was wearing an ankle monitor. However, the court held that ankle monitors are not inherently prejudicial under the standards set by previous cases, including Deck v. Missouri and Holbrook v. Flynn. The court reasoned that ankle monitors are less obtrusive and do not create the same perception of the defendant as shackles do. The court also found that Wiley failed to prove that she was actually prejudiced by the beeping ankle monitor. Therefore, the court affirmed the conviction. View "USA V. WILEY" on Justia Law

The case involves Lorain Ann Stiffler, who applied for disability insurance benefits under the Social Security Act, claiming disability due to attention deficit hyperactivity disorder, depression, a mood disorder, right knee problems, and a processing disorder. Her application was initially denied and denied again upon reconsideration. Dr. Khosh-Chashm, who diagnosed Stiffler with major depressive disorder, concluded that she had extreme mental functioning limitations and lacked the cognitive and communicative skills required for gainful employment. However, state agency medical consultants Dr. Goldberg and Dr. Bilik disagreed, concluding that Stiffler was not disabled but had moderate limitations on her ability to carry out detailed instructions, maintain concentration, work with others, make simple work-related decisions, and complete a normal workday and workweek.The Administrative Law Judge (ALJ) affirmed the denial of Stiffler's application for disability benefits. The ALJ rejected Dr. Khosh-Chashm's opinion, finding it unsupported by and inconsistent with the medical evidence and Stiffler's significant daily activities. The ALJ also found no conflict between the testimony of the vocational expert and the Dictionary of Occupational Titles (DOT), concluding that Stiffler could work as a marking clerk, mail clerk, or laundry worker.The United States Court of Appeals for the Ninth Circuit affirmed the district court's judgment, which had upheld the ALJ's decision. The court found substantial evidence supporting the ALJ's evaluation of Dr. Khosh-Chashm's medical opinion and concluded that there was no conflict between Stiffler's limitation to "an environment with few workplace changes" and the DOT's Reasoning Level 2. View "STIFFLER V. O'MALLEY" on Justia Law