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

A woman alleged that a sheriff’s deputy in Okanogan County, Washington, coerced her into sexual encounters over several years, exploiting her drug addiction and involvement in criminal activity. She claimed that the deputy’s misconduct began in 2014 and continued through 2021, with the deputy using his position to pressure her into unwanted sexual acts in exchange for not pursuing criminal charges against her. The woman also alleged that the sheriff’s office was aware of the deputy’s behavior but failed to take effective action, and that similar misconduct occurred with other deputies and vulnerable women.After the woman filed suit in the United States District Court for the Eastern District of Washington, the defendants moved to dismiss, arguing that her claims were barred by Washington’s three-year statute of limitations. The district court agreed, holding that her claims were untimely and that her allegations did not sufficiently support municipal liability under Monell v. New York City Department of Social Services. The court dismissed her claims with prejudice and denied her request to amend her complaint.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that each alleged act of sexual misconduct constituted a discrete, independently wrongful act for statute of limitations purposes, so claims based on acts within three years of the complaint were timely. For earlier acts, the court found that the plaintiff plausibly alleged a delayed accrual theory, given the power imbalance and her delayed realization of harm. The court also held that the district court abused its discretion by denying leave to amend the Monell claim, as the plaintiff alleged facts supporting a pattern of deliberate indifference. The Ninth Circuit reversed the dismissal of both federal and state law claims and remanded for further proceedings. View "ST. CLAIR V. COUNTY OF OKANOGAN" on Justia Law

A hospital employee in Oregon, who identified as a practicing Christian, requested a religious exemption from her employer’s COVID-19 vaccine mandate, citing her belief that her body is a temple of the Holy Spirit and that she must avoid substances that could harm her body. The employer granted her exemption from vaccination but required her to wear personal protective equipment and undergo weekly antigen testing using a nasal swab treated with ethylene oxide. The employee objected to the testing, claiming her research showed the swab was carcinogenic and that using it would violate her religious duty to protect her body. She requested alternative accommodations, such as saliva testing or full-time remote work, but the employer denied these requests and ultimately terminated her employment when she refused to comply.The United States District Court for the District of Oregon dismissed her complaint for failure to state a claim, finding that her objection to the testing was based on secular, medical concerns rather than a bona fide religious belief. The court concluded that while her general belief in protecting her body as a temple was religious, her specific objection to the nasal swab was rooted in her personal interpretation of medical research.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that to state a claim for religious discrimination under Title VII and Oregon law, a plaintiff must plausibly allege that the specific accommodation request is rooted in a bona fide religious belief, not merely a secular or personal preference. The court found that the employee’s complaint did not sufficiently connect her religious beliefs to her objection to antigen testing, as her concerns were based on her own medical judgment rather than religious doctrine. The court declined to adopt a more lenient pleading standard and affirmed the dismissal with prejudice. View "DETWILER V. MID-COLUMBIA MEDICAL CENTER" on Justia Law

After the Washington Medical Commission adopted a policy to discipline physicians for spreading COVID-19 “misinformation,” several plaintiffs—including physicians who had been charged with unprofessional conduct, physicians who had not been charged, and advocacy organizations—filed suit. The Commission’s actions included investigating and charging doctors for public statements and writings about COVID-19 treatments and vaccines. Some plaintiffs, such as Dr. Eggleston and Dr. Siler, were actively facing disciplinary proceedings, while others, like Dr. Moynihan, had not been charged but claimed their speech was chilled. Additional plaintiffs included a non-profit organization and a public figure who alleged their right to receive information was affected.The United States District Court for the Eastern District of Washington dismissed the plaintiffs’ First Amended Complaint. The court found that the claims were constitutionally and prudentially unripe, and that the doctrine of Younger abstention required federal courts to refrain from interfering with ongoing state disciplinary proceedings. The district court also addressed the merits, concluding that the plaintiffs failed to state a plausible First Amendment or due process claim, but the primary basis for dismissal was abstention and ripeness.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Younger abstention barred claims challenging ongoing state disciplinary proceedings (including as-applied and facial constitutional challenges, and due process claims) for all plaintiffs subject to such proceedings. The court also held that Younger abstention did not apply to claims for prospective relief by plaintiffs not currently subject to proceedings, but those claims were constitutionally and prudentially unripe because no concrete injury had occurred and further factual development was needed. The Ninth Circuit thus affirmed the dismissal of all claims. View "STOCKTON V. BROWN" on Justia Law

A dispute arose over the ownership of a 2021 Mercedes-Benz G63. Phoenix Motor Company (PMC), operating as Mercedes-Benz of Scottsdale, purchased the vehicle through a wholesaler, but the intermediary, Fredrick Aljundi, diverted the car to another dealership instead of delivering it to PMC. Subsequently, Zakia J. Rajabian and Dulceria La Bonita Wholesale (collectively, Dulceria) acquired the car from the second dealership and took steps to conceal its location. PMC, with assistance from Mercedes-Benz USA, located the car using tracking technology.Litigation began in the Maricopa County Superior Court, where PMC sued Dulceria and others for breach of contract and related claims, and Dulceria counterclaimed. The state court initially granted PMC possession of the car and, after further proceedings, found PMC to be the rightful owner. While the state case was ongoing, Dulceria filed a federal lawsuit in the United States District Court for the District of Arizona, asserting claims including invasion of privacy and violations of federal and state statutes. PMC moved to dismiss or stay the federal case under the Colorado River doctrine, which allows federal courts to stay proceedings in favor of parallel state litigation. The district court granted a stay in November 2023 and formalized it in a minute order in December 2023. Dulceria later moved to lift the stay, but the district court denied the motion in April 2024.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the December 2023 minute order constituted a final, appealable order, starting the 30-day appeal period. Because Dulceria did not appeal the initial stay within that period, the court dismissed that portion of the appeal as untimely. The Ninth Circuit affirmed the district court’s denial of the motion to lift the stay, holding that the district court did not abuse its discretion in maintaining the stay under the Colorado River doctrine, as there were no material changes in law or fact to warrant lifting it. View "RAJABIAN V. MERCEDES-BENZ USA, LLC" on Justia Law

Two nonprofit organizations and an individual challenged two provisions of Arizona’s 2023 Election Procedures Manual (EPM). The first provision, known as the Speech Provision, purported to summarize Arizona’s voter intimidation laws and included examples of prohibited conduct, such as using offensive language or engaging in behavior that could be seen as intimidating or harassing voters. The second, the Canvass Provision, described the Secretary of State’s duty to certify statewide election results by a statutory deadline, specifying that if a county failed to submit its official results on time, the Secretary must proceed without including that county’s votes.The plaintiffs filed suit in the United States District Court for the District of Arizona, alleging that the Speech Provision violated their First and Fourteenth Amendment rights by chilling protected political speech, and that the Canvass Provision unconstitutionally burdened the right to vote by threatening disenfranchisement if a county missed the certification deadline. The district court found that the plaintiffs had standing to challenge both provisions, denied a request to stay the case under Pullman abstention, and granted a preliminary injunction enjoining enforcement of both the Speech and Canvass Provisions.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the preliminary injunction as to the Speech Provision, holding that the plaintiffs had standing because they intended to engage in political speech arguably covered by the provision and faced a credible risk of enforcement. The court found a likelihood of success on the merits, as the state did not contest the district court’s conclusion that the Speech Provision likely violated the First and Fourteenth Amendments. However, the Ninth Circuit reversed the district court’s finding of standing regarding the Canvass Provision, concluding that plaintiffs had not shown a substantial risk that any county would fail to certify its results and thus vacated the injunction as to that provision. The case was remanded for further proceedings. View "AMERICAN ENCORE V. FONTES" on Justia Law

A man was arrested after he attempted to meet someone he believed to be a 12-year-old girl for sex, following extensive online and text communications. The “girl” was actually a fictional persona created by law enforcement as part of an undercover operation. After his arrest, officers obtained a warrant to search his residence, where they discovered a large quantity of child pornography on a hard drive. The defendant was charged with attempted coercion and enticement of a minor to engage in illegal sexual activity, as well as possession of child pornography.The United States District Court for the District of Montana denied the defendant’s pretrial motions to suppress the evidence seized from his residence, to sever the two charges in the indictment, and to exclude evidence of his uncharged interactions with a 17-year-old girl. The court found that the search warrant was supported by probable cause, that the charges were properly joined as offenses of similar character, and that the evidence regarding the 17-year-old was admissible to show intent. After a jury convicted the defendant on both counts, the district court sentenced him to 154 months’ imprisonment on each count, to run concurrently.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the conviction and sentence. The court held that the search warrant was supported by probable cause to search for both enticement and child pornography, and that any omission in the warrant affidavit was immaterial. The court also held that the charges were properly joined under Federal Rule of Criminal Procedure 8(a), and that the evidence of the defendant’s relationship with the 17-year-old was properly admitted under Federal Rules of Evidence 404(b) and 403. Finally, the court found that the sentence was substantively reasonable and did not result in unwarranted sentencing disparity. View "USA V. BOUDREAU" on Justia Law

The defendant was indicted for possession with intent to distribute methamphetamine and pled guilty to the charge. At sentencing, he received a prison term of 151 months, three years of supervised release, and was ordered to pay a $1,000 fine and a $100 special assessment. The district court specified that these monetary penalties were “due immediately,” but, recognizing the defendant’s indigency, also established a payment schedule: while incarcerated, he was to make nominal payments through the Bureau of Prisons’ Inmate Financial Responsibility Program, and during supervised release, he was to pay a percentage of his income, subject to a minimum monthly amount.After sentencing, the United States District Court for the District of Idaho entered judgment reflecting both the immediate due date and the payment schedule. The government sent a letter demanding immediate payment of the full amount and warning of a possible judgment lien. The defendant appealed, arguing that 18 U.S.C. § 3572(d)(1) does not permit a court to make monetary penalties due immediately while also setting a payment schedule, contending that the statute requires the court to choose only one of these options.The United States Court of Appeals for the Ninth Circuit reviewed the statutory interpretation issue de novo. The court held that the district court did not violate 18 U.S.C. § 3572(d)(1) by making the fine and special assessment due immediately while also providing a payment schedule. The Ninth Circuit reasoned that the statute allows for the total amount to be due immediately, with a payment schedule reflecting the defendant’s ability to pay, and that this approach is consistent with its own precedent and that of other circuits. The judgment of the district court was affirmed. View "USA V. PATRICK" on Justia Law

A dispute arose between a woman and her daughter regarding the daughter’s alleged misuse of property held in an irrevocable trust for which she served as trustee. The mother initiated a lawsuit in Massachusetts state court, asserting several state-law claims against her daughter and her daughter’s then-husband. Subsequently, the daughter filed for bankruptcy under Chapter 13 in the United States Bankruptcy Court for the District of Arizona, which triggered an automatic stay of the state court litigation. The bankruptcy court initially granted the mother’s motion for relief from the automatic stay and for permissive abstention, allowing the state court case to proceed. However, after delays in the state court proceedings, the daughter moved for relief from that order, and the bankruptcy court vacated its prior order and reimposed the automatic stay.After the bankruptcy court’s March 2021 order reimposing the stay, the mother filed adversary proceedings in bankruptcy court, which were consolidated and tried. The bankruptcy court ruled in favor of the daughter on all claims and entered final judgment in July 2022. The mother then appealed the March 2021 order to the United States District Court for the District of Arizona, arguing that the bankruptcy court erred in granting relief under Rule 60(b)(6) rather than Rule 60(b)(1). The district court concluded that the appeal was timely because it believed the March 2021 order was not immediately appealable, and it affirmed the bankruptcy court’s decision.The United States Court of Appeals for the Ninth Circuit held that, under Ritzen Group, Inc. v. Jackson Masonry, LLC, the bankruptcy court’s March 2021 order was a final, appealable order because it definitively resolved a discrete dispute within the bankruptcy case. Since the mother did not appeal within the required fourteen days, her appeal was untimely, and the district court lacked jurisdiction. The Ninth Circuit vacated the district court’s order and remanded with instructions to dismiss the appeal for lack of jurisdiction. View "FANTASIA V. DIODATO" on Justia Law

Two former customers of an insurance company filed suit after their vehicles were declared total losses and the insurer paid out claims based on the vehicles’ “actual cash value” (ACV). The insurance policy defined ACV as the “market value, age, and condition of the vehicle at the time the loss occurs.” The insurer calculated market value using a system that included a “projected sold adjustment” (PSA), which reduced the list prices of comparable vehicles to reflect typical consumer negotiation. The plaintiffs alleged that the PSA always resulted in an artificially low valuation, breaching the policy’s requirement to pay true market value.The United States District Court for the District of Arizona found that the plaintiffs met the requirements of numerosity, commonality, typicality, and adequacy under Federal Rule of Civil Procedure 23(a). However, the court determined that individual questions about how each vehicle’s ACV was calculated predominated over common questions, as required by Rule 23(b)(3), and therefore denied class certification. The plaintiffs appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of class certification for abuse of discretion. The appellate court held that the PSA was not facially unlawful and that determining whether each class member was harmed would require individualized inquiries into each person’s vehicle valuation. Because liability and injury could not be established through common evidence, individual issues would predominate over common ones. The Ninth Circuit therefore affirmed the district court’s order denying class certification, holding that class certification was inappropriate under Rule 23(b)(3) due to the predominance of individualized questions. View "AMBROSIO V. PROGRESSIVE PREFERRED INSURANCE COMPANY" on Justia Law

Parents and guardians of students enrolled in independent study programs at two California charter schools requested that the schools purchase and allow the use of sectarian curricular materials for instruction. The schools denied these requests, citing California laws that prohibit the teaching of sectarian or denominational doctrine in public schools, including charter schools. The plaintiffs argued that the independent study programs were essentially homeschooling and that the denial of their requests violated their rights under the Free Exercise and Free Speech Clauses of the First Amendment.The United States District Court for the Eastern District of California dismissed the complaint for failure to state a claim. The court found that charter schools are part of California’s public school system and are permitted to provide strictly secular education. It concluded that the plaintiffs were not being excluded from a generally available public benefit because of their religious exercise, as the case involved state-funded public schools rather than private schools. The court also held that a public school’s curriculum constitutes government speech, which is not subject to scrutiny under the Free Speech Clause.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that, even assuming the funding and materials provided in independent study programs are a generally available public benefit, the programs are sufficiently public to allow California to require the use of secular curricula. The court further held that the curriculum decisions of public schools are government speech and thus not subject to the Free Speech Clause. The judgment of the district court was affirmed. View "WOOLARD V. THURMOND" on Justia Law