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

Douglas Eligha Taylor was originally convicted in 1995 for robbing four banks in Los Angeles, pleading guilty to multiple counts including armed bank robbery and using a firearm during a crime of violence. He was sentenced to 147 months in prison and a five-year term of supervised release. After his release in 2007, Taylor committed another bank robbery in 2008 and was prosecuted in state court, receiving a 17-year sentence. While in state custody, he was involved in a stabbing incident and accumulated multiple rules violations. Upon completing his state sentence in 2023, Taylor was transferred to federal custody, where the United States Probation Office petitioned to revoke his supervised release based on his 2008 conduct. Taylor admitted the allegations, and the district court accepted his admissions.The United States District Court for the Central District of California revoked Taylor’s supervised release and imposed a 60-month prison sentence, which was above the recommended Guidelines range of 18–24 months, followed by 24 months of supervised release. The court explained its decision by referencing Taylor’s repeated violations, the danger posed to the public, his lack of deterrence from prior sanctions, and the risk of recidivism. Taylor appealed, arguing that the district court committed procedural error by failing to adequately explain the sentence, improperly considering his prior criminal conduct, and imposing a substantively unreasonable sentence.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not commit plain procedural error, adequately explained its reasons for the above-Guidelines sentence, and properly considered Taylor’s history and risk to the public. The court also found the sentence to be substantively reasonable and rejected Taylor’s arguments for a lower sentence. The judgment was affirmed. View "USA V. TAYLOR" on Justia Law

The Securities and Exchange Commission (SEC) initiated a civil enforcement action against Ongkaruck Sripetch and several other defendants, alleging that they engaged in fraudulent schemes involving at least 20 penny stock companies. The SEC claimed that the defendants obtained over $6 million in illicit proceeds through violations of the Securities Act of 1933 and the Securities Exchange Act of 1934, including securities fraud and the sale of unregistered securities. The SEC sought various remedies, including an order requiring the defendants to disgorge all ill-gotten gains.The United States District Court for the Southern District of California presided over the case. Sripetch consented to the entry of judgment, agreeing that the court could order disgorgement and prejudgment interest, and that the complaint’s allegations would be accepted as true for the purposes of the SEC’s motion. The district court ordered Sripetch to disgorge $2,251,923.16 in net profits, plus prejudgment interest. Sripetch appealed, arguing that disgorgement under 15 U.S.C. § 78u(d)(5) and (d)(7) requires a showing of pecuniary harm to investors, which he claimed the SEC had not demonstrated.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s disgorgement order for abuse of discretion. The Ninth Circuit held that the SEC is not required to show that investors suffered pecuniary harm as a precondition to a disgorgement award under § 78u(d)(5) or (d)(7). The court reasoned that disgorgement is a profits-based remedy focused on depriving wrongdoers of ill-gotten gains, not compensating victims for losses. Accordingly, the Ninth Circuit affirmed the district court’s judgment. View "UNITED STATES SECURITIES AND EXCHANGE COMMISSION V. SRIPETCH" on Justia Law

A religious association that supports abortion as a core tenet challenged Idaho’s laws criminalizing abortion. The organization, which operates a telehealth abortion clinic in New Mexico, alleged that its members in Idaho were harmed by the state’s abortion restrictions. The association claimed that it had members in Idaho who could become involuntarily pregnant and would seek abortions as part of their religious practice, and that it had diverted resources to open its New Mexico clinic in response to Idaho’s and other states’ abortion bans.The United States District Court for the District of Idaho granted the defendants’ motion to dismiss, finding that the association lacked both associational and organizational standing. The district court determined that the association had not identified any specific member in Idaho who was injured or imminently would be injured by the abortion laws, nor had it shown that its organizational activities were directly impeded by the statutes. The district court also addressed the merits of the association’s constitutional claims and dismissed the complaint with prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on the grounds of lack of Article III standing. The Ninth Circuit held that the association failed to demonstrate associational standing because it did not identify any member who had suffered or would imminently suffer an injury in Idaho. The court also found no organizational standing, as the association’s diversion of resources to open a clinic in New Mexico and its claim of frustration of mission were insufficient under recent Supreme Court precedent. The Ninth Circuit did not reach the merits of the constitutional claims. The court remanded the case to the district court to determine whether the complaint could be saved by amendment, noting that dismissal for lack of jurisdiction should generally be without prejudice. View "THE SATANIC TEMPLE V. LABRADOR" on Justia Law

Eight firefighters employed by a regional fire and rescue agency in Washington State requested religious exemptions from a COVID-19 vaccine mandate issued in August 2021 by the state’s governor, which required healthcare providers to be vaccinated. The fire agency, which provides emergency medical and fire services to a large population, including a state prison, allowed employees to seek religious accommodations. After reviewing the requests and consulting with union representatives, the agency determined it could not accommodate unvaccinated firefighters in their roles without imposing an undue hardship on its operations, citing health and safety concerns, operational burdens, and potential financial risks. The firefighters were offered the option to use accrued leave or take a leave of absence, with the possibility of returning if the mandate changed.The firefighters sued in the United States District Court for the Western District of Washington, alleging violations of Title VII of the Civil Rights Act and the Washington Law Against Discrimination for failure to accommodate their religious beliefs. The district court assumed the firefighters had bona fide religious objections but found that accommodating their requests would impose an undue hardship on the agency, given the increased risk of COVID-19 transmission, the large number of exemption requests, and the inadequacy of proposed alternatives such as masking and testing. The court granted summary judgment in favor of the fire agency.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that, under the standard clarified in Groff v. DeJoy, an employer demonstrates undue hardship when the burden of accommodation is substantial in the context of its business. The court found that the fire agency had shown substantial health, operational, and financial costs associated with accommodating the exemption requests, and that the proposed alternatives were insufficient. The summary judgment for the agency was affirmed. View "PETERSEN V. SNOHOMISH REGIONAL FIRE AND RESCUE" on Justia Law

Michael McNeil, an incarcerated individual at Ely State Prison, was accused of smuggling drugs into the facility via the mail system. During his preliminary disciplinary hearing, McNeil requested access to the evidence against him, including the mail and a positive drug test result from the envelopes’ address labels, but his request was denied. At a subsequent formal hearing, a disciplinary committee found him guilty, resulting in the loss of statutory good time credits, canteen privileges, and a referral for criminal prosecution. After his appeals through the prison’s grievance process were denied, McNeil filed a lawsuit under 42 U.S.C. § 1983, alleging that prison officials violated his Fourteenth Amendment due process rights.The United States District Court for the District of Nevada reviewed cross-motions for summary judgment. The court partially granted McNeil’s motion, finding that his due process rights were violated when he was denied access to certain evidence, but identified a genuine dispute regarding other evidence requests. The court denied the defendants’ motion for summary judgment on qualified immunity, holding that it was clearly established that McNeil had a constitutional right to access the evidence against him. The order was entered on the civil docket on May 22, 2023.The United States Court of Appeals for the Ninth Circuit reviewed the case after the defendants filed a notice of appeal 150 days following the district court’s order. The Ninth Circuit held that 28 U.S.C. § 2107(a) requires a notice of appeal to be filed within 30 days after entry of an order denying qualified immunity. The court rejected the defendants’ argument that the Federal Rules of Civil and Appellate Procedure extended the appeal period to 180 days due to the absence of a separate judgment document. The Ninth Circuit concluded that the appeal was untimely and dismissed it for lack of jurisdiction. View "MCNEIL V. GITTERE" on Justia Law

Robinhood Markets, Inc., an online brokerage firm, experienced a surge in business during early 2021 due to increased trading in “meme stocks” and Dogecoin. This activity declined sharply in the second quarter of 2021, leading to significant drops in key financial metrics and performance indicators. In July 2021, Robinhood conducted an initial public offering (IPO) and issued a registration statement that included limited information about its second-quarter performance. After the IPO, Robinhood released its full second-quarter results, which revealed substantial declines and led to a drop in its stock price. Plaintiffs, representing a class of investors, alleged that Robinhood’s registration statement omitted material information about these declines, violating Sections 11, 12, and 15 of the Securities Act of 1933.The United States District Court for the Northern District of California dismissed the plaintiffs’ claims with prejudice. The district court found that Robinhood and its co-defendants were not liable under the Securities Act for failing to disclose the pre-IPO declines in key performance indicators and certain revenue sources. The court also held that there was no actionable omission regarding the increased percentage of Robinhood’s revenue attributable to speculative trading.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. The Ninth Circuit held that the district court applied incorrect legal standards to the plaintiffs’ theories under Section 11’s “misleading” prong and Item 303 of Regulation S-K. The appellate court clarified that, in this context, Sections 11 and 12 require disclosure of all material information, and rejected the “extreme departure” test used by the district court. The court vacated the dismissal as to these theories and remanded for further proceedings. However, the Ninth Circuit affirmed the district court’s dismissal of the claim based on Item 105 of Regulation S-K, finding no duty to provide a breakdown of revenue sources for the relevant period. View "Sodha v. Golubowski" on Justia Law

Hundreds of thousands of Venezuelan nationals living in the United States received Temporary Protected Status (TPS), which allowed them to work and protected them from deportation due to ongoing humanitarian crises in Venezuela. In January 2025, the Secretary of Homeland Security extended TPS for Venezuelans through October 2026, consolidating two prior designations to streamline the process. Shortly after, a new Secretary, following a change in administration, attempted to vacate this extension and terminate TPS for one group of Venezuelan nationals, citing confusion and alleged improvements in Venezuela’s conditions. This abrupt reversal threatened TPS holders with imminent loss of status, employment, and the risk of deportation.The National TPS Alliance and several individual TPS holders filed suit in the United States District Court for the Northern District of California, seeking to restore the extension. The district court granted preliminary relief, postponing the effective dates of the vacatur and termination notices nationwide under the Administrative Procedure Act (APA), finding that plaintiffs were likely to succeed on the merits, would suffer irreparable harm without relief, and that the balance of equities and public interest favored postponement.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s order. The Ninth Circuit held that it had jurisdiction to review the preliminary relief and that neither the TPS statute nor 8 U.S.C. § 1252(f)(1) barred judicial review of the Secretary’s authority. The court concluded that the Secretary lacked statutory authority to vacate a prior extension of TPS, as the statute provides specific procedures for designation, extension, and termination, but not for vacatur. The court also found that nationwide relief was necessary to provide complete relief to the plaintiffs. The district court’s order postponing the vacatur and termination of Venezuelan TPS was affirmed. View "National TPS Alliance v. Noem" on Justia Law

The plaintiff purchased a life insurance policy for her son and consistently paid the required premiums. She alleges that the insurer failed to provide the statutory notices and protections mandated by California law before terminating her policy for nonpayment. After missing a payment in 2016, her policy lapsed, and following reinstatement, it was terminated again in 2018 after another missed payment. The plaintiff contends that the insurer’s failure to comply with statutory notice requirements rendered the termination ineffective and that her experience was representative of many other policyholders in California.The United States District Court for the Eastern District of California granted in part the plaintiff’s motion for class certification. The court found that the prerequisites of Federal Rule of Civil Procedure 23(a) were met and certified a class under Rule 23(b)(2) for declaratory and injunctive relief. The certified class included all policy owners or beneficiaries whose policies lapsed for nonpayment without the required statutory notice. The court appointed the plaintiff as class representative but denied, without prejudice, certification for monetary relief under Rule 23(b)(3).The United States Court of Appeals for the Ninth Circuit reviewed the district court’s class-certification order. Relying on its intervening decision in Small v. Allianz Life Insurance Co. of North America, the Ninth Circuit held that to recover for violations of the relevant California statutes, plaintiffs must show not only a statutory violation but also that the violation caused them harm. The court found that the plaintiff was not an adequate class representative for beneficiaries and that her claims were not typical of class members who intentionally allowed their policies to lapse. The Ninth Circuit reversed the district court’s class-certification order and remanded the case for further proceedings. View "Farley v. Lincoln Benefit Life Co." on Justia Law

After failing to pay property taxes on her home in Maricopa County, Arizona, the plaintiff’s tax liens were sold to a private entity, which later foreclosed on the property. The plaintiff did not respond to the foreclosure action, resulting in a default judgment that extinguished her rights to the property. The property was then deeded to the private purchaser, who transferred it to another private party. The plaintiff subsequently challenged the foreclosure, the retention of surplus equity from the sale, and the constitutionality of the Arizona statute that allowed private parties to enforce tax liens without providing just compensation.The United States District Court for the District of Arizona dismissed the plaintiff’s claims, finding that the Rooker-Feldman doctrine deprived it of subject matter jurisdiction. The court reasoned that the plaintiff’s injuries stemmed from the state court’s foreclosure judgment, which had already extinguished her property rights, and thus her federal claims amounted to an impermissible appeal of a state court decision. The court also dismissed her state law claims, except for one over which it declined supplemental jurisdiction.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed in part and reversed in part. The Ninth Circuit held that the Rooker-Feldman doctrine barred the plaintiff’s claims that directly attacked the state court foreclosure judgment, such as those alleging the foreclosure was an unconstitutional taking or excessive fine. However, the court held that claims challenging the defendants’ post-judgment retention of surplus equity were not barred, in light of the Supreme Court’s decision in Tyler v. Hennepin County, which recognized a property owner’s right to excess equity after a tax foreclosure. The court also found that the plaintiff’s facial challenge to the statute was not barred by Rooker-Feldman but was moot due to legislative amendments. The case was remanded for further proceedings on the surviving claims. View "SEARLE V. ALLEN" on Justia Law

Paul Schwartz, while incarcerated at a federal correctional facility in Tucson, alleged that prison officials were deliberately indifferent to his serious medical needs over an eighteen-month period. He experienced a range of severe symptoms, including tachycardia, blood in his urine, and significant thyroid dysfunction, but claimed he received inadequate and delayed medical care despite repeated attempts to seek help. Schwartz specifically alleged that a mid-level practitioner, Ms. Tatad, refused to provide treatment or access to a physician and instructed others to deny him care. He also claimed that the warden and associate warden ignored his efforts to alert them to his condition, resulting in irreversible kidney injury and other long-term health risks.The United States District Court for the District of Arizona initially dismissed several defendants and later granted summary judgment for the remaining defendants. On appeal, the United States Court of Appeals for the Ninth Circuit reversed in part, allowing Schwartz’s claim against Tatad to proceed. After remand, the district court denied Schwartz’s motion to amend his complaint, then later granted Tatad’s motion for judgment on the pleadings, concluding that the Prison Litigation Reform Act (PLRA) constituted a special factor that placed Schwartz’s claim in a new Bivens context, foreclosing a damages remedy.The United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The Ninth Circuit held that Schwartz’s claim was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, which recognized a Bivens remedy for Eighth Amendment claims of deliberate indifference to serious medical needs. The court found that neither the PLRA, the Bureau of Prisons’ Administrative Remedy Program, nor the factual specifics of Schwartz’s case created a new Bivens context. The court also held that the district court abused its discretion in denying Schwartz leave to amend his complaint. View "SCHWARTZ V. MILLER" on Justia Law