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

In the case before the United States Court of Appeals for the Ninth Circuit, Best Carpet Values, Inc. and Thomas D. Rutledge initiated a class action lawsuit against Google, LLC. The plaintiffs argued that Google, through its Search App on Android phones, displayed their websites in a way that occupied valuable space for which Google should have paid. They contended that Google received all the benefits of advertising from the use of that space. The plaintiffs made state-law claims for trespass to chattels, implied-in-law contract and unjust enrichment, and violation of California's Unfair Competition Law.The court reviewed questions certified by the district court for interlocutory review. In response to the first question, the court ruled that the website copies displayed on a user's screen should not be protected as chattel, concluding that a cognizable property right did not exist in a website copy. As a result, the plaintiffs’ trespass to chattels claim was dismissed.Addressing the third question, the court held that website owners cannot invoke state law to control how their websites are displayed on a user's screen without being preempted by federal copyright law. The court determined that the manner in which the plaintiffs’ websites were displayed fell within the subject matter of federal copyright law. It also found that the rights asserted by the plaintiffs’ implied-in-law contract and unjust enrichment claim were equivalent to the rights provided by federal copyright law. Thus, the plaintiffs’ state-law claim was preempted by federal copyright law.Given these findings, the court did not address the other certified questions. The Ninth Circuit concluded that the district court erred in denying Google’s motion to dismiss and remanded the case with instructions to dismiss. View "Best Carpet Values, Inc. v. Google LLC" on Justia Law

In this case, Alexander Hebrard, an inmate in Oregon, brought a complaint under 42 U.S.C. § 1983 alleging that he was disciplined in prison without due process of law. Hebrard claimed that he was found guilty of prison rule violations without sufficient evidence and was denied the opportunity to present a defense. As a result of his alleged wrongful conviction, Hebrard was fined, had money confiscated from his prison account, was placed in segregated housing, lost visitation rights, and had earned-time credits revoked. In his lawsuit, Hebrard sought damages for all these sanctions, except for the revocation of his earned-time credits. The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of Hebrard's complaint as barred by Heck v. Humphrey. Under Heck, a claim for damages that would necessarily imply the invalidity of the length of an inmate's sentence must be dismissed unless the inmate first challenges his sentence in a habeas corpus proceeding and obtains relief. The Ninth Circuit determined that even though Hebrard did not seek relief for the revocation of his earned-time credits, his claim nonetheless implicated the validity of his disciplinary conviction, which in turn affected the length of his sentence. The court concluded that Hebrard needed to obtain habeas relief before filing this § 1983 action. Because he did not do so, his claim was barred by Heck. View "Hebrard V. Nofziger" on Justia Law

In this case, the United States Court of Appeals for the Ninth Circuit reversed the district court's dismissal of an ERISA action brought by South Coast Specialty Surgery Center, Inc. against Blue Cross of California, d/b/a Anthem Blue Cross.South Coast, a healthcare provider, sought reimbursement from Blue Cross for the costs of medical services provided to its patients. South Coast argued that although it was not a plan participant or a beneficiary under ERISA, it had the right to enforce ERISA's protections directly because its patients had assigned it the right to sue for the non-payment of plan benefits via an "Assignment of Benefits" form. The district court disagreed and dismissed South Coast's suit, concluding that the form only conveyed the right to receive direct payment from Anthem, and not the right to sue for non-payment of plan benefits.The Ninth Circuit held that a healthcare provider can enforce ERISA's protections if it has received a valid assignment of rights. The court determined that South Coast's patients had effectuated a valid assignment through the "Assignment of Benefits" form. Therefore, South Coast had the right to seek payment of benefits and to sue for non-payment. The court reversed the lower court's decision and remanded the case for further proceedings. View "SOUTH COAST SPECIALTY SURGERY CENTER, INC. V. BLUE CROSS OF CALIFORNIA" on Justia Law

In a case involving a putative class of plaintiffs who alleged that the Superior Court of Los Angeles County and Judge Eric C. Taylor set cash bail that they could not afford and unlawfully detained them pretrial, the United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of the action. The court held that actions against state courts and state court judges in their judicial capacity are barred by Eleventh Amendment immunity. The Superior Court of California was found to have sovereign immunity as an arm of the state. The court concluded that the exception in the Ex parte Young case did not apply because the Superior Court cannot be sued in an individual capacity. The court also held that Judge Taylor had Eleventh Amendment immunity because state court judges cannot be sued in federal court in their judicial capacity under the Eleventh Amendment. The court overruled any interpretation of a previous case (Wolfe v. Strankman) that suggested the Ex parte Young exception allowed injunctions against judges acting in their judicial capacity, finding such interpretation to be clearly irreconcilable with a more recent Supreme Court decision (Whole Woman’s Health v. Jackson). The court concluded that it lacked jurisdiction to resolve claims brought against state courts or state court judges acting in a judicial capacity due to Eleventh Amendment immunity. View "MUNOZ V. SUPERIOR COURT OF LOS ANGELES COUNTY" on Justia Law

This case was brought by the plaintiffs-appellants, David Cassirer, the Estate of Ava Cassirer, and the United Jewish Federation of San Diego County, against the Thyssen-Bornemisza Collection Foundation, an instrumentality of the Kingdom of Spain. The case centers around a painting by French Impressionist Camille Pissarro, which was stolen by the Nazis in 1939 Germany. The painting eventually came into the possession of the Thyssen-Bornemisza Collection, which has publicly displayed it in Madrid, Spain since 1993. When the plaintiffs learned of the painting's location in 2000, they petitioned for its return, but were denied, leading to the present lawsuit filed in 2005.The case hinged on whether Spanish or California law should govern the determination of ownership of the painting. Under Spanish law, the defendant would retain the painting, having gained prescriptive title through possession for over three years in good faith. Under California law, the plaintiffs would recover the painting, as a thief cannot pass good title to stolen property.The United States Court of Appeals for the Ninth Circuit, on remand from the United States Supreme Court, applied California’s three-step “governmental interest analysis” for choice-of-law disputes. The court found that there was a true conflict between the laws of Spain and California, and that each jurisdiction had a legitimate interest in applying its laws to the case. The court then resolved the conflict by applying the law of the jurisdiction whose governmental interests would be more impaired if its law were not applied. The court concluded that Spain’s governmental interests would be more impaired by the application of California law than would California’s governmental interests be impaired by the application of Spanish law. Thus, Spanish law applied, and the Thyssen-Bornemisza Collection had gained prescriptive title to the painting. The court affirmed the district court’s judgment in favor of the Thyssen-Bornemisza Collection. View "CASSIRER V. THYSSEN-BORNEMISZA COLLECTION" on Justia Law

The case concerned a lawsuit brought by Ariana Miles against her former employer, Kirkland's Stores Inc., alleging that two of the company's employee policies violated California law. The first policy required employees to take rest breaks on store property, while the second necessitated employees to undergo bag checks when they finished their shifts. Miles sought class certification for subclasses of employees affected by these two policies from May 2014 to the present. The United States Court of Appeals for the Ninth Circuit reversed the district court's denial of class certification for subclasses related to the Rest Break Claim due to the inaccuracy of the district court's finding that the rest break policy was inconsistently applied. The court held that overwhelming record evidence indicated that the company consistently enforced its rest break policy across all employees. However, the court upheld the district court's denial of class certification for the Bag Check Claim, as the evidence suggested that the bag check policy was sporadically enforced, which would require individualized inquiries. The case was thus remanded for further proceedings concerning the Rest Break Claim. View "MILES V. KIRKLAND'S STORES, INC." on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the decision of the District Court, which denied attorneys' fees and nontaxable costs under the Equal Access to Justice Act (EAJA) to the defendants-appellants, Brian Bowers, Dexter Kubota, and Bowers + Kubota Consulting, Inc. The Department of Labor had alleged that the defendants sold their company to an employee stock ownership plan (ESOP) at an inflated value. The government's case relied on a single valuation expert, whose opinion was ultimately rejected by the District Court, resulting in the government losing the case. Nonetheless, the District Court found that the government's litigation position was "substantially justified." On appeal, the Ninth Circuit held that the District Court did not abuse its discretion in concluding that the government's position at trial was substantially justified, and thus, in denying attorneys' fees and nontaxable costs under EAJA. The Court also held that the District Court abused its discretion in reducing the award of taxable costs, as it was based on a clearly erroneous finding of fact. Therefore, the case was remanded for reconsideration of the award of taxable costs. View "SU V. BOWERS" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the decision of the district court, which upheld the Commissioner of Social Security's denial of a claimant's application for supplemental security income. The claimant argued that the Social Security Administration's 2017 revised regulations for evaluating medical opinions were partially invalid because they did not provide a reasoned explanation for permitting an administrative law judge to avoid articulating how he or she accounts for the "examining relationship" or "specialization" factors under the Social Security Act or the Administrative Procedure Act (“APA”). The court found that the Commissioner's decision to promulgate the 2017 medical evidence regulations fell within his wide latitude to make rules and regulations, particularly those governing the nature and extent of the proofs and evidence to establish the right to benefits. The court also joined the Eleventh Circuit in holding that the regulations were valid under the APA, as the agency's response to public comment and reasoned explanation for the regulatory changes established that the regulations were not arbitrary or capricious. View "CROSS V. O'MALLEY" on Justia Law

In this case, Zachary Silbersher, a relator, filed a qui tam action under the False Claims Act against Valeant Pharmaceuticals International, Inc. and others. Silbersher alleged that Valeant fraudulently obtained patents related to a drug and asserted these patents to stifle competition from generic drugmakers. He also claimed that Valeant defrauded the federal government by charging an artificially inflated price for the drug while falsely certifying that its price was fair and reasonable.The district court dismissed Silbersher’s action under the False Claims Act’s public disclosure bar, ruling that his allegations had already been publicly disclosed. The United States Court of Appeals for the Ninth Circuit reversed the decision of the district court.The Court of Appeals held that an inter partes patent review proceeding, in which the Patent and Trademark Office invalidated one of Valeant's patents, did not qualify as a public disclosure under the False Claims Act because the government was not a party to that proceeding, and its primary function was not investigative. The Court of Appeals also held that the allegations in Silbersher's qui tam action were not "substantially the same" as the information that had been publicly disclosed. None of the qualifying public disclosures made a direct claim that Valeant committed fraud, nor did they disclose a combination of facts sufficient to permit a reasonable inference of fraud. Therefore, the public disclosure bar did not apply. The case was remanded for further proceedings. View "SILBERSHER V. VALEANT PHARMACEUTICALS INT'L" on Justia Law

In the case reviewed, Mario Gonzalez-Godinez was convicted for attempted illegal entry under 8 U.S.C. § 1325(a) after being found near a border fence and admitting to being a Mexican citizen without documentation. After his arrest, a Border Patrol agent read him his Miranda rights as well as his immigration-related administrative rights. Gonzalez waived both sets of rights and then confessed to having been smuggled across the border. Gonzalez argued on appeal that the Miranda warning was inadequate and his conviction should be vacated under the corpus delicti doctrine. The United States Court of Appeals for the Ninth Circuit rejected both arguments.Firstly, the court ruled that the Miranda warning was not inadequate despite also warning Gonzalez that the post-arrest interview may be his only chance to seek asylum. While these two warnings may have posed difficult decisions for Gonzalez, the court found them to be neither contradictory nor confusing. The court held that the government did not need to provide further clarification to the Miranda warning.Secondly, the court held that the corpus delicti doctrine, which requires some evidence to support a confession, did not require vacating Gonzalez's conviction. The court found that sufficient evidence supported Gonzalez’s confession, as he had twice admitted to being a Mexican citizen and his behavior at the border supported his confession. Thus, the court affirmed Gonzalez’s conviction. View "USA V. GONZALEZ-GODINEZ" on Justia Law