U.S. Court of Appeals for the Ninth Circuit - Justia Case Law Summaries

ORR V. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, RIVERSIDE

2026-06-09T08:32:53-08:00

A former seasonal employee of a package delivery company filed suit against her employer, alleging violations of California labor laws, including wage-related claims and a Private Attorneys General Act (PAGA) claim. She had signed an arbitration agreement as a condition of employment, which included a class action waiver and a delegation clause assigning threshold arbitrability issues to an arbitrator. The agreement specified that the Federal Arbitration Act (FAA) would govern unless it did not apply, in which case state law would control. After her work schedule was repeatedly changed or canceled with little notice, she was not given further work despite her inquiries and subsequently initiated legal action on behalf of herself and proposed classes. After the case was removed from state court, the United States District Court for the Central District of California granted the employer’s motion to compel arbitration of the individual claims and stayed class claims. The district court declined to decide whether the FAA or the California Arbitration Act (CAA) governed the agreement, reasoning that the result would be the same under either statute. The court also denied the employee’s motion for clarification, maintaining that the question of which law applied and whether the FAA’s “contracts of employment” exclusion was relevant could be resolved by the arbitrator rather than the court. On mandamus review, the United States Court of Appeals for the Ninth Circuit held that the district court committed clear legal error by failing to determine whether the FAA or state law governed the arbitration agreement before compelling arbitration. The Ninth Circuit emphasized that, under New Prime Inc. v. Oliveira, the court—not an arbitrator—must decide whether the FAA applies, including any statutory exclusions. The Ninth Circuit granted the writ of mandamus, directing the district court to vacate its prior order and to determine the statutory basis for its authority to compel arbitration before referring the parties to arbitration. View "ORR V. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, RIVERSIDE" on Justia Law

FORWARD, INC. V. MACOMBER

2026-06-09T08:32:52-08:00

Forward, Inc. operates a landfill near Stockton, California, which is bordered by several state facilities. Forward was required by a local water quality board to remediate groundwater contamination at its landfill. During this process, Forward suspected that nearby state facilities—including correctional and health care centers—were contributing hazardous waste to the groundwater, hindering its remediation efforts. Forward entered into an agreement with two California state agencies to access these facilities and collected data suggesting ongoing hazardous waste generation stemming from activities such as dry cleaning, solvent use, and well-water treatment at the state facilities. Forward filed suit in the United States District Court for the Eastern District of California under the Resource Conservation and Recovery Act (RCRA), seeking injunctive and declaratory relief against the Secretary of the California Department of Corrections and Rehabilitation (CDCR) and the Director of the California Department of General Services (DGS). Forward alleged that, due to their official positions, these defendants had control over the generation, handling, storage, and disposal of hazardous waste at the relevant facilities. The district court granted the defendants’ motion to dismiss for lack of subject matter jurisdiction, concluding that Forward had not established a sufficiently direct connection between the defendants and the alleged violations under the Ex parte Young exception to Eleventh Amendment sovereign immunity. The United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. It affirmed the district court’s ruling, holding that Forward failed to establish the “fairly direct” connection required by Ex parte Young. The court found that the defendants’ general supervisory roles over their respective agencies did not suffice to subject them to suit for the alleged RCRA violations, as neither their statutory duties nor alleged actions were directly tied to the waste management at the specific state facilities. The Ninth Circuit’s disposition was to affirm the district court’s dismissal. View "FORWARD, INC. V. MACOMBER" on Justia Law

CIRIA V. GERRANS

2026-06-05T09:33:05-08:00

Joaquin Ciria was convicted in 1991 for the murder of Felix Bastarrica in San Francisco, based largely on the testimony of George Varela, who was 18 at the time and an accomplice to the actual shooter. The conviction rested primarily on Varela’s statement, which he later recanted, claiming that police investigators threatened him with prosecution and fed him a story implicating Ciria. There was no physical evidence linking Ciria to the crime, and eyewitnesses could not positively identify him. In 2022, after serving thirty-two years, Ciria was exonerated when new evidence and witness statements showed he was factually innocent, and it was revealed that the investigators had used coercive tactics during their interrogation of Varela. Following his exoneration, Ciria filed a federal civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of California. He alleged that San Francisco Police Inspectors James Crowley and Arthur Gerrans fabricated evidence and maliciously prosecuted him. The district court denied Crowley and Gerrans’s motion for qualified immunity on Ciria’s fabrication-of-evidence and malicious prosecution claims, concluding that a reasonable jury could find the officers had used coercive interrogation tactics and lacked probable cause to charge Ciria. On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of qualified immunity. The court held that, viewing the facts in the light most favorable to Ciria, a reasonable jury could find that the officers threatened and coerced a key witness into fabricating evidence against Ciria and that, as of 1990, it was clearly established that such conduct would violate due process rights. The Ninth Circuit also held that the officers were not entitled to qualified immunity on the malicious prosecution claim because, without the coerced statement, it was not reasonably arguable that probable cause existed to charge Ciria. The court’s decision was affirmed. View "CIRIA V. GERRANS" on Justia Law

PIZZUTO V. VALLEY

2026-06-05T08:31:39-08:00

In 1985, Gerald Ross Pizzuto, Jr. was convicted by a jury in Idaho state court of murdering Berta and Del Herndon during a robbery, and he was sentenced to death. Over the following decades, Pizzuto challenged his conviction and death sentence through numerous state and federal post-conviction proceedings, but those efforts were unsuccessful. In 2021, Pizzuto sought clemency from the Idaho Commission of Pardons and Parole, which recommended that his death sentences be commuted to life without parole. However, the Governor of Idaho rejected this recommendation in accordance with an Idaho statute requiring gubernatorial approval for commutation in capital cases. Following the Governor’s denial, Pizzuto argued in Idaho state court that the Governor lacked authority under the Idaho Constitution to overrule the Commission’s recommendation. The Idaho Supreme Court upheld the statute granting the Governor final authority in capital commutation cases, concluding that a 1986 amendment to the Idaho Constitution permitted the legislature to establish the procedures for granting clemency. Pizzuto filed a petition for rehearing, asserting that the Idaho Supreme Court’s decision was so arbitrary as to violate his federal due process rights, but the Idaho Supreme Court summarily denied rehearing. Pizzuto then brought a habeas corpus petition in the United States District Court for the District of Idaho, raising the due process claim. The district court denied relief, finding that the claim was not cognizable in federal habeas and would fail on the merits. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that Pizzuto’s claim essentially challenged the Idaho Supreme Court’s interpretation of state law, which is not a cognizable federal habeas claim. Even if the claim were cognizable, the court determined that Pizzuto did not demonstrate a due process violation under clearly established federal law, and the Idaho Supreme Court’s decision was not so arbitrary as to support habeas relief. View "PIZZUTO V. VALLEY" on Justia Law

USA V. DEBORBA

2026-06-04T15:01:12-08:00

The defendant entered the United States in 1999 and remained without legal status after his tourist visa expired in 2000. He applied for and received a Washington concealed pistol license in 2019, falsely claiming to be a U.S. citizen. He also submitted Bureau of Alcohol, Tobacco, Firearms, and Explosives forms indicating citizenship to register handguns. A series of domestic violence incidents led to multiple restraining orders against him, each including a prohibition on owning or possessing firearms. Law enforcement seized firearms, ammunition, and a silencer from his residence in 2022. The defendant admitted to being a Brazilian citizen and acknowledged that he was not permitted to possess firearms due to his immigration status and domestic violence convictions. The United States District Court for the Western District of Washington denied the defendant’s motions to dismiss charges on Second Amendment, materiality, and vagueness grounds. The defendant was convicted in a bench trial based on stipulated facts for unlawful possession of firearms and ammunition as a noncitizen and as a person under a domestic violence restraining order, making false statements during firearm purchases, falsely claiming U.S. citizenship, and unlawful possession of a firearm silencer. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed all convictions. The court held that precedent from United States v. Vazquez-Ramirez controlled challenges to 18 U.S.C. § 922(g)(5)(A), confirming the constitutionality of prohibiting firearm possession by noncitizens unlawfully present. Materiality challenges to false statement convictions failed because the Second Amendment does not protect firearm possession by such individuals. The court found that United States v. Rahimi and United States v. VanDyke foreclosed challenges to convictions based on domestic violence restraining orders. The court held that the National Firearms Act’s silencer regulations do not violate the Second Amendment or the Fifth Amendment’s vagueness doctrine. The panel affirmed the district court’s judgment. View "USA V. DEBORBA" on Justia Law

PEOPLE OF THE STATE OF CAL. V. FMCSA

2026-06-04T15:01:11-08:00

California officials challenged a determination by the Federal Motor Carrier Safety Administration (FMCSA) that California’s meal and rest break (MRB) rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted by federal law. The MRB rules require employers to provide drivers with specified meal and rest periods during the workday. The FMCSA concluded that these state rules regulated commercial motor vehicle safety, were more stringent than federal hours-of-service (HOS) regulations, and imposed requirements not found in federal law. Previously, in 2019, the American Bus Association petitioned the FMCSA to preempt California’s MRB rules for passenger-carrying drivers. After public notice and comment, the FMCSA issued a final order in 2020 preempting these rules, finding they added no measurable safety benefit beyond federal HOS rules, were incompatible with federal regulations, and placed an unreasonable burden on interstate commerce. California officials petitioned the United States Court of Appeals for the Ninth Circuit for review of the FMCSA’s preemption decision. The United States Court of Appeals for the Ninth Circuit reviewed the FMCSA’s action under the highly deferential standard of the Administrative Procedure Act. It held that its earlier decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021), foreclosed California’s main arguments and confirmed that the FMCSA had authority to preempt the MRB rules. The court also held that the FMCSA’s determination that the MRB rules imposed an unreasonable burden on interstate commerce was supported by the administrative record and not arbitrary or capricious. The petition for review was denied, and the FMCSA’s preemption determination was upheld. View "PEOPLE OF THE STATE OF CAL. V. FMCSA" on Justia Law

COFFEY V. FAST EASY OFFER, LLC

2026-06-04T15:01:11-08:00

The plaintiff, an Arizona resident, registered her personal cell phone on the national “do not call” registry in 2004. She alleged that a real estate company, Fast Easy Offer, LLC, and related entities, contacted her through at least six phone calls and two text messages in the fall of 2024. The messages asked if she had given up on selling her property. According to the plaintiff, Fast Easy Offer’s business model involves purchasing homes below market value and remarketing them, and if a home is not purchased, the lead is given to a real estate brokerage, Keller Williams Realty Phoenix, with revenues shared. The plaintiff claimed that the purpose of these communications was to solicit the purchase of real estate brokerage services. The plaintiff filed a putative class action in the United States District Court for the District of Arizona, alleging violations of the Telephone Consumer Protection Act (TCPA). The defendants moved to dismiss, arguing that the communications did not qualify as “telephone solicitations” under the Act and that Keller Williams Realty, Inc. was not vicariously liable. The district court granted the motion, dismissing the complaint with prejudice. The court held that the calls and texts were not telephone solicitations because they did not expressly encourage the purchase of services. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. It held that under the TCPA’s definition, and consistent with Chesbro v. Best Buy Stores, L.P., 705 F.3d 913 (9th Cir. 2012), the plaintiff had adequately pleaded that the messages qualified as telephone solicitations. The court concluded that the purpose of initiation of the calls or messages is determinative, and the plaintiff’s allegations about defendants’ intent sufficed. The Ninth Circuit reversed the district court’s dismissal and remanded for further proceedings. View "COFFEY V. FAST EASY OFFER, LLC" on Justia Law

WELSH V. LOUDBEAR

2026-06-04T15:01:11-08:00

Kyle and Jill Welsh, members of the Colorado River Indian Tribes (CRIT) and owners of WW Young Money, LLC, leased tribal land to operate a smoke shop. After renewing their lease in 2020, tribal officials notified the Welshes in 2021 that their lease was terminated, alleging violations of the CRIT property code, including untimely rent payments, continued occupancy after a demand to vacate, and property damage. The Welshes responded by filing a civil RICO action in federal court, alleging that the tribal officials engaged in a pattern of racketeering activity that included illegal lease termination, conversion of inventory, extortion, and providing false information to law enforcement. The United States District Court for the District of Arizona dismissed the complaint. It held that the tribal officials were entitled to sovereign immunity because their alleged conduct occurred within the scope of their authority and in their representative capacities. The court also ruled that CRIT was a required party under Federal Rule of Civil Procedure 19, as it had a legally protected interest in the lease, and that the action could not continue without the tribe, whose joinder was barred by sovereign immunity. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the tribal officials were not entitled to sovereign immunity because they were sued in their individual capacities for money damages, and any recovery would come from them personally, not from CRIT. The appellate court also determined that CRIT was not a required party because the outcome would not affect its real property or contractual rights, as the plaintiffs did not seek to reinstate the lease. The Ninth Circuit reversed the district court’s dismissal under Rules 12(b)(1) and 12(b)(7) and remanded for consideration of whether the complaint states a valid claim and if leave to amend should be granted. View "WELSH V. LOUDBEAR" on Justia Law

CONOCOPHILLIPS ALASKA, INC. V. ALASKA OIL AND GAS CONSERVATION COMMISSION

2026-05-27T08:32:45-08:00

ConocoPhillips Alaska, Inc., an oil and gas producer, conducted drilling operations in the National Petroleum Reserve-Alaska, a federal property located within the territorial bounds of Alaska. As required by federal lease terms and the Naval Petroleum Reserves Production Act, ConocoPhillips submitted well data to the U.S. Department of the Interior. To comply with Alaska law, it also submitted a subset of that data to the Alaska Oil and Gas Conservation Commission. Alaska law requires such well data to be kept confidential for 24 months, after which it must be disclosed to the public unless certain additional confidentiality conditions are met. ConocoPhillips sought to prevent the Commission from releasing this data, citing concerns about the loss of trade secrets. After the Alaska Department of Natural Resources denied ConocoPhillips’s request to extend the confidentiality period, ConocoPhillips filed suit in the United States District Court for the District of Alaska, seeking declaratory and injunctive relief. The district court denied the Commission’s motion to dismiss, granted partial summary judgment to ConocoPhillips, and entered final judgment in its favor. The district court concluded that while the federal Production Act did not expressly preempt Alaska law, it did impliedly preempt the state’s disclosure provision because releasing the data would conflict with the purposes of the federal statute. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo and reversed the district court’s decision. The Ninth Circuit held that the Production Act does not expressly preempt Alaska’s disclosure statute, nor do Department of the Interior regulations do so. The court also found there was no implied preemption, as the Production Act does not demonstrate a congressional intent that would be obstructed by Alaska’s law. Thus, Alaska’s disclosure requirements were not preempted by federal law. View "CONOCOPHILLIPS ALASKA, INC. V. ALASKA OIL AND GAS CONSERVATION COMMISSION" on Justia Law

USA V. JOHNSEN

2026-05-26T08:01:14-08:00

Law enforcement identified an individual using the eMule peer-to-peer file-sharing platform who was sharing files with hash values matching those of known child pornography. The account was traced to the defendant, who had a prior record of offenses involving minors. Despite being unable to directly download the flagged files from the defendant’s account, agents matched the hash values and observed filenames indicative of child pornography. The officers obtained a search warrant, searched the defendant’s residence, and seized numerous electronic devices. Forensic analysis uncovered tens of thousands of images and hundreds of videos containing child pornography. The United States District Court for the District of Arizona reviewed several pretrial motions. The defendant moved to suppress evidence, arguing the search warrant lacked probable cause since agents had not visually confirmed the files’ content and that the review of his publicly shared files violated his Fourth Amendment rights and the Wiretap Act. The defendant also moved to dismiss the indictment, claiming prejudice from forensic analysis conducted without counsel present, and argued selective prosecution due to his status as a registered sex offender. Following hearings, the district court denied all motions. After a jury convicted the defendant on all counts, the court also denied his Rule 29 motion for judgment of acquittal, and sentenced him to concurrent prison terms and supervised release. The United States Court of Appeals for the Ninth Circuit affirmed the conviction. The court held that hash value matches, even without visual confirmation, provided probable cause to support the search warrant, especially when reinforced by descriptive filenames and the defendant’s criminal history. The court found no Fourth Amendment or Wiretap Act violations because the files had been made publicly available. It ruled there was no right to counsel during the non-critical stage of forensic analysis and found no evidence supporting selective prosecution. The court declined to review the sufficiency of the evidence claim due to lack of argumentation. View "USA V. JOHNSEN" on Justia Law

THAKUR V. TRUMP

2026-05-26T08:01:13-08:00

Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support. The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law

HEDRINGTON V. USA

2026-05-22T08:01:17-08:00

The case involves Orlonzo Hedrington, who underwent heart surgery and subsequent rehabilitation at a Veterans Administration medical center in California. Hedrington alleged that, during his discharge, he was sexually assaulted by nursing staff and administered drugs to disguise the assault. He filed a timely administrative claim with the Department of Veterans Affairs, which was denied. Hedrington then filed a timely lawsuit under the Federal Tort Claims Act (FTCA), claiming negligence. The United States District Court for the Eastern District of California first reviewed Hedrington’s timely FTCA action (“Hedrington I”). The United States moved for summary judgment, raising issues related to judicial estoppel and standing due to Hedrington’s bankruptcy proceedings. After the bankruptcy trustee was substituted as plaintiff, the district court denied the United States’s summary judgment motion. Later, Hedrington filed a second, untimely pro se lawsuit (“Hedrington II”), which was removed to the same district court. The court dismissed Hedrington II as time-barred under the FTCA. Subsequently, the United States moved for summary judgment in Hedrington I, asserting claim preclusion based on the judgment in Hedrington II. The district court granted summary judgment on both claim preclusion and insufficient evidence. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Hedrington I was not barred by claim preclusion. Following Filice v. United States, the Ninth Circuit applied California claim preclusion law, under which a dismissal for untimeliness does not have claim preclusive effect. Additionally, the court found that applying claim preclusion here would result in manifest injustice, triggering California’s public policy exception. The Ninth Circuit reversed the district court’s summary judgment on claim preclusion and remanded for further proceedings. View "HEDRINGTON V. USA" on Justia Law

OLSON V. FCA US, LLC

2026-05-21T08:01:11-08:00

Jeffrey Olson leased a Jeep Grand Cherokee from a car dealership under a lease agreement that included an arbitration provision and a delegation clause, which assigned questions about the scope of arbitration to an arbitrator. FCA US, LLC, the manufacturer of the Jeep, was not a signatory to the lease agreement. Olson later became the named plaintiff in a federal class-action lawsuit against FCA, alleging defects in the vehicle’s headrest system. FCA, not being a party to the lease, sought to compel Olson to arbitrate the dispute based on the arbitration agreement between Olson and the dealership. The United States District Court for the Eastern District of California denied FCA’s motion to compel arbitration. The district court found that FCA, as a non-signatory to the lease agreement, could not enforce the arbitration provision or its delegation clause against Olson. The court concluded that the arbitration agreement applied only to Olson and the dealership (including its employees, agents, successors, or assigns), and FCA did not qualify under any of those categories. Additionally, the court rejected FCA’s argument that it could use equitable estoppel to compel arbitration, holding that none of Olson’s claims were sufficiently intertwined with the lease agreement to justify such an exception under California law. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that FCA could not compel Olson to arbitrate because FCA was not a party to the arbitration agreement and no applicable exception—such as equitable estoppel—applied. The court clarified that, under both federal and California law, only parties to an arbitration agreement (or those qualifying under specific, limited exceptions) may enforce it. The court also rejected FCA’s reliance on Supreme Court precedent, finding it inapplicable to non-signatories in these circumstances. View "OLSON V. FCA US, LLC" on Justia Law

USA V. TEKOLA

2026-05-20T08:01:43-08:00

Federal agents identified the defendant as the source of fentanyl that caused a fatal overdose in Goleta, California. Their investigation revealed that he had been selling drugs for years, frequently operating from his apartment. A search of the apartment uncovered nearly $13,000 in cash, various tools associated with drug distribution, and significant quantities of cocaine, fentanyl, methamphetamine, and Alprazolam. The defendant admitted that the cash was proceeds from drug dealing and that a safe in his bedroom was primarily used to store drugs and drug proceeds. His phone also contained substantial evidence indicating his apartment functioned as the center of his drug-trafficking activities. A grand jury indicted the defendant for possession with intent to distribute multiple controlled substances. He pleaded guilty to all charges without a plea agreement. At sentencing, the United States District Court for the Central District of California considered—over defense objection—a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a premises for the purpose of manufacturing or distributing a controlled substance. The defendant argued that his apartment was primarily his residence, not a stash house, and that the enhancement should not apply. The district court found ample evidence that the apartment was used as a place to sell drugs and imposed the enhancement, ultimately sentencing the defendant to 105 months’ imprisonment. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s application of the sentencing enhancement for abuse of discretion and affirmed the sentence. The court held that the enhancement under § 2D1.1(b)(12) applies when a defendant regularly uses his home for substantial drug trafficking, even if the residence also serves as his primary home. The Ninth Circuit found no abuse of discretion in the district court’s determination that drug trafficking was a primary or principal use of the apartment. The sentence was affirmed. View "USA V. TEKOLA" on Justia Law

TRAMMELL V. KLN ENTERPRISES, INC.

2026-05-15T08:31:24-08:00

A consumer purchased a licorice product manufactured by a Minnesota company, relying on packaging that stated the product was “Naturally Flavored,” “Natural Strawberry & Raspberry Flavored Licorice,” and “Free of . . . Artificial Colors & Flavors.” The consumer later learned, through laboratory testing, that the product contained DL malic acid, which is an artificial flavor created from petrochemical sources. The consumer alleged that this ingredient rendered the product’s labeling false or misleading, and filed a putative class action in California, asserting claims for violation of the California Consumers Legal Remedies Act, unjust enrichment, and breach of express warranty. The United States District Court for the Southern District of California dismissed the complaint with prejudice. The court found that the complaint failed to plead with sufficient particularity that the malic acid was artificial, thus not meeting the heightened pleading standard of Federal Rule of Civil Procedure 9(b). The district court also held that the plaintiff did not plausibly allege that a reasonable consumer would be misled by the product’s labeling, reasoning that the labels did not explicitly state the product was “all natural” or “100% natural,” and that the ingredients list disclosed both natural and artificial ingredients. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The appellate court held that the complaint satisfied Rule 9(b) because it identified the specifics of the alleged fraud and provided details about the laboratory testing. The court also held that the plaintiff plausibly alleged that a reasonable consumer could be misled by the product’s claim to be free of artificial flavors when it allegedly contained an artificial flavor. The case was remanded for further proceedings. View "TRAMMELL V. KLN ENTERPRISES, INC." on Justia Law

BRADFORD V. VANG

2026-05-14T08:01:17-08:00

A man was convicted in California state court of first-degree murder, rape, and sodomy arising from the 1988 killing of a woman at an apartment lodge where both lived. On the day of the crime, the man consumed large amounts of alcohol and interacted repeatedly with the victim, ultimately assaulting and killing her in her apartment. Physical evidence and the man’s own detailed post-arrest confessions were central to the prosecution’s case; he admitted to deliberating about ensuring the victim’s death after an initial assault. The defense at trial argued intoxication, but the jury convicted him of first-degree murder and found a special circumstance, leading to a death sentence. After the California Supreme Court affirmed the convictions and special circumstances (but reversed a robbery charge), the man pursued state and federal habeas relief. His federal habeas petition alleged, among other things, that the prosecution withheld exculpatory blood-alcohol test results (a Brady claim) and that trial counsel was ineffective for failing to investigate and present additional evidence of intoxication and mental impairment (Strickland claims). The U.S. District Court for the Central District of California initially denied most relief but later set aside the murder conviction and special circumstance finding based on the Brady and Strickland claims. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court. The Ninth Circuit held that under AEDPA’s deferential standards, the California Supreme Court could reasonably have concluded that there was insufficient factual support for the existence of undisclosed blood-alcohol test results and that counsel’s alleged failures did not prejudice the defense. The Ninth Circuit directed the district court to deny habeas relief as to the convictions and special circumstances, remanding solely for resolution of any remaining penalty-phase claims. View "BRADFORD V. VANG" on Justia Law

YUROK TRIBE V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

2026-05-13T08:01:14-08:00

Decabromodiphenyl Ether (decaBDE) is a flame retardant used in numerous products, including electronics, vehicles, and appliances, and is known for its persistence, bioaccumulation, and toxic effects on human and environmental health. In response to concerns about such chemicals, Congress amended the Toxic Substances Control Act (TSCA) in 2016, adding a subsection mandating expedited risk-management rules for certain chemicals, including decaBDE. The Environmental Protection Agency (EPA) promulgated rules in 2021 and amended them in 2024, regulating some uses of decaBDE but declining to regulate exposures arising from recycling, disposal, wastewater, and sewage sludge in several contexts. Following the 2021 rule, several petitioners challenged the EPA’s approach in the United States Court of Appeals for the Ninth Circuit. The EPA voluntarily sought a remand to reconsider aspects of its rule, which the Ninth Circuit granted. After seeking additional public comment, the EPA issued the 2024 amendments, which still did not address all the petitioners’ concerns, particularly regarding the areas of recycling, disposal, wastewater discharges, and sewage sludge. The petitioners renewed their challenge, arguing that EPA’s failure to regulate these areas violated TSCA’s mandate. The United States Court of Appeals for the Ninth Circuit concluded that the EPA’s decisions not to further regulate decaBDE exposures in recyclable articles, disposal, wastewater, and sewage sludge were not supported by substantial evidence as required by TSCA. The court held that EPA could not justify a failure to regulate based on low exposure levels or general policy preferences and found the agency had not adequately addressed evidence in the record. The court granted the petition for review, remanded the rule to the EPA for renewed rulemaking and further proceedings, but left the 2024 rule in place during the remand. View "YUROK TRIBE V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY" on Justia Law

USA V. SANCHEZ

2026-05-12T08:01:15-08:00

The defendant, a person of Mexican descent, worked at a tax preparation business serving Spanish-speaking clients in Boise, Idaho. He was indicted on seven counts of preparing and presenting false and fraudulent tax returns. During jury deliberations, it became undisputed that one juror made racially biased comments about Mexicans. This juror, identified as Juror 5, participated in nearly all deliberations and expressed views suggesting animus toward Mexicans, including remarks about how Mexicans "hate Americans" and allegations connecting the defendant's employer to criminal activity. After the biased statements were reported, the United States District Court for the District of Idaho conducted a special voir dire with all jurors to determine the impact of the comments. Several jurors confirmed hearing the remarks, but most denied being influenced by them. The district court excused Juror 5 for good cause but allowed the remaining eleven jurors to continue deliberations without instructing them to start anew. Thirteen minutes later, the jury returned a partial verdict. The defendant moved for a mistrial and later for a new trial, arguing that his Sixth Amendment right to an impartial jury was violated. The district court denied both motions, applying the standard from United States v. Sarkisian, which asks whether exposure to prejudicial comments tainted the verdict. On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court applied an incorrect legal standard. The Ninth Circuit concluded that the proper standard is from United States v. Remmer, which presumes prejudice when juror bias is discovered before a verdict is accepted, and places a heavy burden on the government to prove harmlessness. The court found that the government failed to rebut this presumption, and therefore reversed the district court’s denial of the motion for a new trial and remanded for a new trial. View "USA V. SANCHEZ" on Justia Law

USA V. CHAPMAN

2026-05-08T08:01:18-08:00

John Chapman, who has multiple neurodevelopmental disorders, maintained a romantic relationship with Jamie Feden for several years, despite being married to another woman. In 2019, Chapman and Feden traveled together from Pennsylvania to Las Vegas. Prior to and during this period, Chapman conducted online searches related to murder and body disposal. While in Nevada, Chapman took Feden to a remote desert location, restrained her with zip ties and duct tape under the pretense of a bondage photoshoot, and ultimately caused her death by asphyxiation. He left her body in the desert and returned to Pennsylvania, where he used her phone to communicate with her friends and family to conceal her death. After suspicions arose, Chapman was questioned by police and confessed to the crime after being read his Miranda rights. The United States District Court for the District of Nevada denied Chapman’s motion to suppress his confession, finding that he had knowingly and intelligently waived his Miranda rights and that his confession was voluntary. During trial, Chapman argued his mental conditions affected his perception and intent. After lengthy deliberations and substantive jury notes indicating a deadlock, the district court gave an Allen charge and made coercive comments to a holdout juror. The jury returned a guilty verdict for kidnapping resulting in death. Chapman’s post-verdict motions for acquittal and a new trial were denied. The United States Court of Appeals for the Ninth Circuit vacated Chapman’s conviction and remanded for a new trial, finding impermissible jury coercion due to the undisclosed jury notes, the coercive Allen charge, and the court’s direct comments to a holdout juror. The court also held, for the first time in the circuit, that the “holding” element of the federal kidnapping statute can be satisfied by non-physical means such as deception. The court affirmed the denial of the motion to suppress Chapman’s confession. View "USA V. CHAPMAN" on Justia Law

URQUIA-YANEZ V. BLANCHE

2026-05-08T08:01:17-08:00

A native and citizen of Honduras entered the United States without admission or parole and was taken into custody. Shortly after her release, the Department of Homeland Security (DHS) served her with a Notice to Appear, written in English, which informed her of the obligation to notify the immigration court of any change of address. She provided an address in Hanford, California, which was used for subsequent correspondence. After moving to a new address without notifying the immigration court, she missed a scheduled removal hearing, and was ordered removed in absentia. The Immigration Judge (IJ) denied her motion to reopen the removal proceedings, finding that she had received proper notice by mail to her last known address. Her subsequent motion to reconsider was also denied; the IJ found she had constructive notice because the Notice to Appear was sent to her last provided address, and that she had been properly informed of her obligation to update her address. On appeal, the Board of Immigration Appeals (BIA) upheld the IJ’s decisions, concluding that jurisdiction was not impacted by the allegedly defective Notice to Appear, and that mailing the Notice of Hearing to her last provided address was sufficient under the applicable statutory and Supreme Court precedent. On review, the United States Court of Appeals for the Ninth Circuit held that DHS is not constitutionally required to provide a translation of the entirety of a Notice to Appear—including the obligation to update an address—in an alien’s native language. The court found that English-language notices are generally sufficient to satisfy due process because they are reasonably calculated to inform recipients of their obligations. The petition for review was denied. View "URQUIA-YANEZ V. BLANCHE" on Justia Law

PHILLIPS V. GOLDMAN

2026-05-07T18:01:14-08:00

A creditor and her law firm, holding pre-bankruptcy judgments against a debtor, sought to recover assets from the debtor's Chapter 7 bankruptcy estate. The debtor had declared bankruptcy in 2011, disclosing interests in two Los Angeles properties. The Chapter 7 trustee initially reported no assets available for distribution. After protracted litigation regarding exemptions and the value of the properties, including appeals, the creditor asserted the trustee had failed to preserve estate assets by allowing the properties to deteriorate and by not collecting rental income that could benefit the estate. The creditor began an adversary proceeding against the trustee, alleging gross negligence and breach of fiduciary duty related to the management of estate property. The United States Bankruptcy Court for the Central District of California dismissed the complaint with prejudice, finding the trustee was protected by quasi-judicial immunity because the conduct amounted, at most, to ordinary negligence and was time-barred. On appeal, the United States District Court for the Central District of California affirmed dismissal on the grounds of immunity, but reversed the statute of limitations ruling and remanded for consideration of whether amendment of the complaint would be futile. Upon further appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, held it had jurisdiction to review the district court’s order, given the creditor’s counsel’s representation that they would not amend the complaint. The Ninth Circuit clarified that a bankruptcy trustee may have quasi-judicial immunity only for actions involving discretionary judgment essential to adjudicating private rights in the estate. The court held that the trustee’s alleged failures in property management and rent collection were administrative, not adjudicative, and thus not protected by quasi-judicial immunity. The court also found the trustee was not entitled to derived judicial immunity on the current record. The decision of the district court was reversed and remanded for further proceedings. View "PHILLIPS V. GOLDMAN" on Justia Law

FUHR V. CITY OF SEATTLE

2026-05-07T09:04:36-08:00

The case concerns a police shooting in Seattle involving an officer and an individual named Shaun Fuhr. Fuhr threatened the mother of his infant daughter, fired a handgun in a public park, and then fled on foot with the child. Despite police commands to stop and a search involving a helicopter and SWAT officers, Fuhr continued to evade authorities for over thirty minutes while still holding his daughter. Eventually, SWAT officers, including Noah Zech, encountered Fuhr in a residential alley. As Fuhr appeared from behind bushes, advancing with the infant in his arms, Zech fired a single shot, killing Fuhr. The baby was unharmed, and Fuhr’s gun was later found nearby. Prior to this appeal, the United States District Court for the Western District of Washington granted summary judgment in favor of Zech and the City of Seattle. The district court held that Zech was entitled to qualified immunity on the excessive force claim under 42 U.S.C. § 1983 and dismissed the plaintiffs’ other claims, including negligence, wrongful death, and claims under state law. The plaintiffs appealed these rulings. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that, even when viewing the facts in the light most favorable to the plaintiffs, Zech did not violate clearly established law by shooting Fuhr under these circumstances. The court found no precedent clearly establishing a Fourth Amendment violation in a case involving a fleeing, possibly armed suspect holding a child after firing a gun and ignoring police commands. Accordingly, Zech was entitled to qualified immunity. The court also affirmed the dismissal of the plaintiffs’ remaining claims. View "FUHR V. CITY OF SEATTLE" on Justia Law

CRAIN WALNUT SHELLING, LP V. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

2026-05-07T09:04:35-08:00

The case concerns the process for selecting a lead plaintiff in a securities fraud class action brought under the Private Securities Litigation Reform Act (PSLRA). After investors filed federal securities claims against a company and its executives, several parties moved to be appointed as lead plaintiff, including Crain Walnut Shelling, LP. Crain Walnut reported the largest financial losses among the movants and made a prima facie showing of adequacy and typicality, initially making it the presumptive lead plaintiff. However, a competing movant, Universal, challenged Crain Walnut’s adequacy, raising concerns about inaccuracies in Crain Walnut’s filings and inconsistent representations about its ownership and organizational structure. During discovery, further issues arose when Crain Walnut’s representative gave problematic deposition testimony, indicating an unwillingness to comply with potential discovery obligations. The United States District Court for the Northern District of California evaluated these challenges. After initial proceedings and discovery, the district court concluded that the evidence raised doubts about Crain Walnut’s adequacy but initially applied a “genuine and serious doubt” standard. Ultimately, Universal was appointed as lead plaintiff after the district court found that Crain Walnut’s adequacy was rebutted based on the evidence. Crain Walnut then petitioned the United States Court of Appeals for the Ninth Circuit for a writ of mandamus to vacate the district court’s orders. The Ninth Circuit clarified that the correct standard for rebutting the PSLRA’s presumption of adequacy is the preponderance of the evidence, not a lower standard. The appellate court held that, even under the correct standard, the district court did not commit clear error in finding Crain Walnut inadequate, and thus mandamus relief was not warranted. The court therefore denied the petition for writ of mandamus. View "CRAIN WALNUT SHELLING, LP V. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA" on Justia Law

BURNEY V. BROOMFIELD

2026-05-07T08:31:42-08:00

Three defendants, including the petitioner, were convicted in California state court for the robbery, kidnapping, and murder of a victim who was forced into a car trunk and subsequently killed. The petitioner, who was 18 at the time, confessed to police after being advised of his Miranda rights. At trial, the judge made several offhand, jocular, and at times insensitive comments, including remarks touching on race, gender, and capital punishment. The petitioner did not testify and raised claims at various points about judicial bias and misconduct, an involuntary confession, invalid Miranda waiver, and the improper admission of codefendants’ statements. After conviction and a death sentence, the petitioner’s direct appeal and two state habeas petitions were denied by the California Supreme Court, which rejected his claims both on the merits and on procedural grounds. The petitioner then filed a federal habeas petition in the United States District Court for the Central District of California, which denied relief. The district court also denied a request to expand the certificate of appealability to include claims regarding his confession and the admission of codefendants’ statements. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of habeas relief. The court held that the petitioner’s claims of judicial bias and misconduct failed because the trial judge’s comments, while inappropriate, did not demonstrate actual bias or render the trial fundamentally unfair under the Due Process Clause. The Ninth Circuit also declined to expand the certificate of appealability, finding that the petitioner’s claims regarding the voluntariness of his confession, the validity of his Miranda waiver, and any Bruton violation were not debatable among reasonable jurists and that any error was harmless in light of overwhelming evidence of guilt. The denial of habeas relief was affirmed. View "BURNEY V. BROOMFIELD" on Justia Law

VERICOOL WORLD, LLC V. IGLOO PRODUCTS CORP.

2026-05-06T09:32:01-08:00

A manufacturer of biodegradable coolers developed and released its product several years before a competing company launched a similar cooler. The first manufacturer’s early product was initially not available in retail stores but was later marketed directly to consumers. The competing company’s cooler, introduced later, was sold in major retail chains. The dispute arose when the second company advertised its cooler as the “world’s first eco sensitive cooler, made from 100% biodegradable materials.” The first manufacturer objected, asserting that these statements were false because it had marketed a biodegradable cooler before its competitor. The first manufacturer sued in the United States District Court for the Northern District of California, alleging false advertising under the Lanham Act and unfair competition under California law. The claim was that the competitor’s statements about being “first” deprived it of recognition, market cachet, and associated goodwill, causing harm to its reputation and marketing opportunities. The district court held that the Lanham Act does not provide a cause of action for claims based on inventorship or being “first to market” and granted summary judgment to the defendant. The court found the state law claim derivative and dismissed it as well. 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 Lanham Act, actionable false advertising must concern observable characteristics of the tangible product, not the origin of ideas or claims of market primacy. It concluded that statements about which company was first to market refer to the origin of a concept, not the qualities or characteristics of the product itself, and thus are not cognizable under the Lanham Act. The court also found that the plaintiff had waived any argument that consumers were confused about whether its product was biodegradable. The judgment for the defendant was affirmed. View "VERICOOL WORLD, LLC V. IGLOO PRODUCTS CORP." on Justia Law

WILLIAMS V. LEGACY HEALTH

2026-05-06T08:01:12-08:00

A group of employees working at a regional healthcare system sought religious exemptions from their employer’s COVID-19 vaccination policy, which was instituted in August 2021 amid the rise of the Delta variant. These employees, whose positions required close contact with patients or staff, timely applied for religious exemptions, but their requests were denied. As a result, most were placed on administrative leave and then terminated; one employee eventually complied with the policy and returned to work. The employees brought claims for religious discrimination under Title VII of the Civil Rights Act and Washington state law in the United States District Court for the Western District of Washington. The district court assumed the employees established a prima facie case of religious discrimination but granted summary judgment for the employer. The court found that the employer had demonstrated that granting the exemptions would impose a substantial burden on its ability to provide quality healthcare, citing risks to staffing, patient safety, and overall operations, and that the employees failed to rebut this showing. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s summary judgment in favor of the employer. The Ninth Circuit held that, under the standard articulated in Groff v. DeJoy, an employer must show a substantial burden in the overall context of its business, not merely a de minimis cost, to establish undue hardship. The court determined that the healthcare employer’s evidence of substantial risks to health, safety, and operations sufficed to establish undue hardship. The court also clarified that an employer is not required to prove exclusively financial hardship, nor to provide individualized accommodations if any accommodation would present an undue hardship. The judgment of the district court was affirmed. View "WILLIAMS V. LEGACY HEALTH" on Justia Law

TWENTY-NINE PALMS BAND OF MISSION INDIANS V. BLANCHE

2026-05-06T08:01:11-08:00

A federally recognized tribe in southern California operated a wholesale tobacco distribution business, selling cigarettes exclusively to other California tribes. These tribal businesses, in turn, sold the cigarettes to individual consumers on their respective reservations. Neither the distributing tribe nor its customers held state licenses to distribute or sell cigarettes, and no state cigarette taxes were collected at any point in the distribution chain. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) placed the tribe on the Prevent All Cigarette Trafficking (PACT) Act’s noncompliant list, which restricts delivery of cigarettes by common carriers, due to violations of California’s cigarette tax and licensing laws. After the California Department of Justice notified the tribe of noncompliance, the state asked ATF to add the tribe to the noncompliant list. The tribe responded by arguing the PACT Act did not apply to its sales, but continued to make sales without appropriate licenses or tax payments. ATF issued notices of violations and, after considering the tribe’s responses, confirmed its decision to list the tribe. The tribe then filed suit in the United States District Court for the Central District of California, challenging ATF’s actions as contrary to law and procedurally deficient. The district court granted summary judgment to ATF, finding that the agency’s decision was adequately reasoned and procedurally proper. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The court held that the tribe’s remote cigarette sales to other tribes constituted “off-reservation” activity subject to California’s licensing and tax laws. The court found that the tribe’s customers were “consumers” under the PACT Act, rendering the tribe a “delivery seller” required to comply with state law. The court also held that ATF did not violate the Administrative Procedure Act’s procedural requirements. The decision of the district court was affirmed. View "TWENTY-NINE PALMS BAND OF MISSION INDIANS V. BLANCHE" on Justia Law

3PAK LLC V. CITY OF SEATTLE

2026-05-05T08:01:13-08:00

In June 2020, following the murder of George Floyd, protestors established the Capitol Hill Occupied Protest (CHOP), occupying a sixteen-block area in Seattle’s Capitol Hill neighborhood. In response, the Seattle Police Department abandoned its East Precinct and significantly reduced police presence in the affected area, including Cal Anderson Park. The protests and encampments continued to cause disruption, vandalism, and crime for months, with CHOP forcibly disbanded on July 1, 2020, but neighborhood disturbances persisting until December 2020. Two businesses located near Cal Anderson Park, one a restaurant and the other a property owner, claimed that the City’s actions and inaction led to severe economic losses, including lost revenue, property damage, and tenant departures. Previously, these businesses were absent putative class members in the Hunters Capital, LLC v. City of Seattle class action in the United States District Court for the Western District of Washington, which raised similar claims. After class certification was denied and the case settled, the businesses filed individual lawsuits in April and June 2023, consolidated in the district court. The district court dismissed the state-created danger and Takings Clause claims, and found their nuisance claims untimely under the applicable two-year statute of limitations, but did not initially decide on equitable tolling pending further guidance from the Washington Supreme Court. After the Campeau v. Yakima HMA, LLC decision, the district court dismissed the nuisance claims and entered final judgment. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of the state-created danger and Takings Clause claims, holding that the state-created danger doctrine does not extend to purely economic harm and that the cessation of police services did not constitute a compensable taking. However, the appellate court reversed the dismissal of the nuisance claims, holding that equitable tolling under American Pipe is available under Washington law, and remanded for further proceedings on those claims. View "3PAK LLC V. CITY OF SEATTLE" on Justia Law

DOERR V. SHINN

2026-05-04T10:01:17-08:00

A man was convicted by a jury in Arizona of kidnapping, sexual assault, and murder in 1996, and received a death sentence from a judge. After his conviction was affirmed on direct appeal by the Arizona Supreme Court, he sought postconviction relief in state court, but his counsel failed to investigate or present any claim of ineffective assistance of counsel (IAC) at the sentencing phase. The first postconviction relief (PCR) attorney never met with him and was unaware of the need to investigate sentencing issues. No mitigating evidence or penalty-phase IAC claim was presented to the state courts at that time. The state trial court dismissed his initial PCR petition, and the Arizona Supreme Court denied further review. He then filed a federal habeas petition, raising, for the first time, claims that his trial and PCR counsel were ineffective at sentencing and arguing that he was ineligible for execution due to intellectual disability. The United States District Court for the District of Arizona found his claims procedurally defaulted because they had not been presented in state court and Arizona law generally bars such successive claims. The district court also found that ineffective assistance of PCR counsel did not excuse the default. After the Supreme Court’s decision in Martinez v. Ryan, which allowed ineffective PCR counsel as cause to excuse certain procedural defaults, the case was remanded for further consideration. New mitigating evidence was presented, but subsequent Supreme Court jurisprudence (Shinn v. Ramirez) prevented the federal court from considering evidence not first presented to the state court. The United States Court of Appeals for the Ninth Circuit held that it was not clear whether Arizona courts would find the penalty-phase IAC claim procedurally barred and, applying Rhines v. Weber, granted a stay and abeyance. This allows the petitioner to return to state court to present his unexhausted IAC claim, as the Rhines criteria were satisfied: good cause existed, the claim was potentially meritorious, and there was no intentional delay. The court remanded with instructions to stay federal proceedings pending state court exhaustion of the claim. View "DOERR V. SHINN" on Justia Law

SANCHEZ GONZALEZ V. DEPARTMENT OF STATE

2026-04-30T08:32:23-08:00

A Mexican national who entered the United States unlawfully in 1992 married a U.S. citizen, and together they had three children who are U.S. citizens. In seeking to obtain lawful permanent residency, the noncitizen husband traveled to Mexico for a required consular interview. After the interview, the consular officer denied his visa application, citing 8 U.S.C. § 1182(a)(3)(A)(ii) (“3A2”) and concluding there was reason to believe he was a member of a known criminal organization. The denial notice referenced a review of interview statements, law enforcement information, the immigration record, and all documents submitted. The applicant had no criminal record and disputed gang affiliation, contending that his tattoos were the basis for suspicion. The couple filed suit in the United States District Court for the Central District of California, asserting that the visa denial was based solely on the noncitizen’s tattoos, violated their First Amendment rights, and that 3A2 was unconstitutionally vague. The district court dismissed the case, finding the noncitizen could not overcome the doctrine of consular nonreviewability, and that the U.S. citizen spouse had not plausibly alleged the absence of a facially legitimate and bona fide reason for the visa denial. The court also rejected the vagueness challenge to 3A2. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that the noncitizen could not rely on his own First Amendment rights to challenge the visa denial, but the U.S. citizen spouse’s First Amendment right to receive information was implicated, triggering the narrow Mandel exception to consular nonreviewability. Nevertheless, applying the limited review allowed, the court found the government provided a facially legitimate and bona fide reason for denial, the applicants did not show bad faith, and the relevant statute was not unconstitutionally vague as applied. The judgment of the district court was affirmed. View "SANCHEZ GONZALEZ V. DEPARTMENT OF STATE" on Justia Law

SCOTT V. BROOMFIELD

2026-04-29T08:31:41-08:00

In this case, the petitioner was convicted of first-degree murder with special circumstances after he brutally assaulted a woman, set her on fire, and left her to die. The victim survived for ten months before dying from complications related to her injuries. The petitioner had previously pleaded guilty to rape and attempted murder relating to the same incident, but after the victim’s eventual death, he was charged with murder and sentenced to death following a bench trial. His confessions to law enforcement, as well as physical evidence and eyewitness testimony, connected him to the crime. After his conviction and sentence were affirmed by the California Supreme Court, the petitioner filed several state habeas petitions, arguing that his trial counsel was ineffective in various respects during both the guilt and penalty phases. The California Supreme Court denied relief, often adopting the factual findings of a referee appointed to conduct an evidentiary hearing. The referee found trial counsel credible and discounted much of the petitioner’s new evidence as lacking credibility or being recently fabricated. The petitioner then sought federal habeas relief in the United States District Court for the Central District of California. The district court granted relief based on cumulative ineffective assistance of counsel at the guilt phase, finding that trial counsel’s multiple deficiencies prejudiced the petitioner. On appeal, the United States Court of Appeals for the Ninth Circuit applied the deferential standards required by the Antiterrorism and Effective Death Penalty Act. The court concluded that the California Supreme Court had reasonably determined that trial counsel was not deficient in most respects and that any errors did not result in prejudice sufficient to undermine confidence in the outcome. The Ninth Circuit therefore reversed the district court’s grant of habeas relief and remanded for consideration of the petitioner’s remaining claims. View "SCOTT V. BROOMFIELD" on Justia Law

PUBLIC INTEREST LEGAL FOUNDATION, INC. V. NAGO

2026-04-28T08:02:19-08:00

A nonprofit organization focused on election integrity requested that Hawaii’s State Elections Office provide a statewide list of registered voters, citing a provision in the National Voter Registration Act of 1993 (NVRA) that allows for public inspection of certain election records. Hawaii’s State Elections Office declined to provide the statewide list and recommended that the organization seek separate county-level lists from each of the four County Clerks, as the Office does not maintain or distribute such a combined list. After receiving this response, the organization sought injunctive and declaratory relief in federal court, arguing that the NVRA entitled it to the statewide voter list. The United States District Court for the District of Hawaii dismissed the action, holding that the organization’s claim was not ripe because it had not first requested the information from the counties. The court found there was no Article III jurisdiction, as the organization had not suffered a concrete injury and could still pursue county-level records. The district court allowed time for the organization to amend its complaint if its claims became ripe, but the organization declined, maintaining that the NVRA required disclosure by the State. Final judgment was entered, and the organization appealed. The United States Court of Appeals for the Ninth Circuit reviewed the case and determined that the organization did have standing, as the denial of information requested under the NVRA constitutes a sufficient injury for Article III purposes. The appellate court also found the claim to be ripe, as the State had made clear it would not provide the requested information. However, on the merits, the Ninth Circuit held that the NVRA does not require disclosure of a statewide voter list, as such a list is not a record “concerning the implementation” of list-maintenance programs under the statute. The court therefore affirmed dismissal, but on the merits, and remanded with instructions to dismiss the claim with prejudice. View "PUBLIC INTEREST LEGAL FOUNDATION, INC. V. NAGO" on Justia Law

HANAN V. UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES

2026-04-27T08:01:39-08:00

A noncitizen from Israel entered the United States on a tourist visa, overstayed, and married a U.S. citizen (his first wife). They divorced less than two years later, and no immigration benefit was sought based on that marriage. Years later, the noncitizen married another U.S. citizen, with whom he has a child. His current wife filed a petition (Form I-130) for him to be classified as an immediate relative, a necessary step toward permanent residency. The U.S. Citizenship and Immigration Services (USCIS) denied this petition, concluding the noncitizen’s prior marriage was a sham, entered solely to obtain immigration benefits. The Board of Immigration Appeals (BIA) upheld USCIS’s denial, finding the noncitizen’s first marriage was fraudulent. The plaintiffs then challenged the decision in the United States District Court for the Northern District of California, arguing that the marriage fraud bar in 8 U.S.C. § 1154(c) should not apply since no immigration benefit had been sought from the first marriage, and that their procedural due process rights had been violated by the reliance on the ex-wife’s statement without cross-examination. The district court granted summary judgment to the government. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s grant of summary judgment. The Ninth Circuit held that, under the plain meaning of 8 U.S.C. § 1154(c)(2), the marriage fraud bar applies when a noncitizen attempts or conspires to enter into a marriage for the purpose of evading immigration laws, regardless of whether an immigration benefit was sought. The court also held that the plaintiffs received adequate procedural due process and that substantial evidence supported the agency’s finding of marriage fraud. The Ninth Circuit affirmed the district court’s decision. View "HANAN V. UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES" on Justia Law

FORWARD, INC. V. MACOMBER

2026-04-27T07:32:10-08:00

A company operating a landfill in California suspected that neighboring state facilities were contributing hazardous waste, complicating its efforts to clean up groundwater contamination. The company alleged that activities at several state-run institutions bordering its landfill—including a correctional facility and a health care center—involved the use and disposal of hazardous substances that were leaching into the groundwater. In response, the company entered into an agreement allowing it to collect data from these state facilities, which it then used to support its claim that hazardous waste generation at those sites was undermining its remediation efforts. The company brought a lawsuit in the United States District Court for the Eastern District of California, seeking injunctive and declaratory relief under the Resource Conservation and Recovery Act (RCRA) against the Secretary of the California Department of Corrections and Rehabilitation and the Director of the California Department of General Services. The lawsuit alleged that, by virtue of their official positions, these state officials controlled the generation and management of hazardous waste at the implicated facilities. The district court dismissed the case for lack of subject-matter jurisdiction, concluding that the officials’ general supervisory roles were insufficient to establish the “fairly direct” connection to the alleged violations required for an exception to Eleventh Amendment sovereign immunity under the doctrine established in Ex parte Young. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff failed to demonstrate a “fairly direct” connection between the named officials and the alleged RCRA violations. The court clarified that general supervisory authority or oversight of state agencies does not, by itself, subject state officials to suit under Ex parte Young; a more specific connection to the alleged unlawful conduct is required. Thus, the action against these particular officials could not proceed. View "FORWARD, INC. V. MACOMBER" on Justia Law

COUNTY OF SAN BERNARDINO V. INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA

2026-04-23T08:31:16-08:00

The dispute centers on insurance coverage for environmental remediation costs incurred by a county at an airport property it owned. The activities causing contamination began during and after World War II, including industrial waste disposal and manufacturing by various tenants. In the 1990s and beyond, state authorities ordered the county to investigate and clean up hazardous groundwater pollution. The county sought coverage under a series of insurance policies issued by its insurer between 1966 and 1975, which provided both excess and umbrella liability coverage. The core disagreement was whether the insurer’s liability for property damage was limited to $9 million per occurrence, as the county argued, or subject to a $9 million annual aggregate limit, as the insurer contended. Initially, the United States District Court for the Central District of California allowed the insurer to withdraw an admission that no aggregate limit applied. The district court ultimately sided with the insurer, holding that the policies imposed an annual aggregate limit on property damage claims and relying on a California appellate decision, Garamendi v. Mission Insurance Co., to support this view. After granting the insurer’s motion, the district court dismissed the county’s claim for declaratory relief, reasoning that no further controversy existed and that any determination of future benefits would be speculative. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that, under California law, the aggregate limit provisions in these policies were ambiguous regarding whether they applied to property damage. The court found that Garamendi did not bind its interpretation, considering the policies’ language and extrinsic evidence, including industry practice and the insurer’s own statements. Concluding the policies did not specify an aggregate limit for property damage, the Ninth Circuit reversed the district court’s judgment and remanded for further proceedings. View "COUNTY OF SAN BERNARDINO V. INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA" on Justia Law

PETREY V. PRINCESS CRUISE LINES, LTD.

2026-04-23T08:01:14-08:00

A hotel guest, who was staying at a lodge as part of a cruise package, fell in his bathroom after tripping over a raised shower ledge situated close to the toilet. He alleged that the bathroom’s configuration was unreasonably dangerous, and that the cruise line and hotel operator were negligent in constructing or maintaining that configuration. The guest asserted both a traditional maritime negligence claim and an alternative theory of negligence per se, arguing that the bathroom violated applicable plumbing codes. The United States District Court for the Central District of California granted summary judgment for the defendants on both theories. Regarding the negligence claim, the district court ruled that the plaintiff had not provided evidence that the defendants had actual or constructive notice of the alleged dangerous condition. On the negligence per se theory, the district court found that there was insufficient evidence that a plumbing code violation caused the plaintiff’s injury. The United States Court of Appeals for the Ninth Circuit reviewed the case. The appellate court held that, because the defendants owned and constructed the lodge’s bathroom, there was no dispute that they knew or should have known the configuration existed. It found that the plaintiff’s expert evidence created a genuine dispute about whether the defendants knew or should have known that the configuration was unreasonably dangerous. Therefore, the Ninth Circuit vacated the district court’s summary judgment on the maritime negligence claim. However, the appellate court agreed with the district court that the defendants were entitled to summary judgment on the negligence per se theory, concluding that a movable shower curtain did not violate the cited plumbing code. The Ninth Circuit affirmed summary judgment for the defendants on negligence per se and remanded the general negligence claim for further proceedings. View "PETREY V. PRINCESS CRUISE LINES, LTD." on Justia Law

USA V. STATE OF CALIFORNIA

2026-04-22T09:06:03-08:00

California enacted the No Vigilantes Act, which requires non-uniformed federal law enforcement officers operating in the state to visibly display identification while performing enforcement duties, with certain exceptions. Officers who fail to comply face potential criminal prosecution under California law. The law also provides a safe harbor: if a law enforcement agency maintains and posts a written policy requiring visible identification, the agency and its personnel are exempt from the identification mandate and associated penalties. The United States filed suit in the United States District Court for the Central District of California, challenging the constitutionality of the Act’s identification requirement (Section 10) and related provisions, arguing that these provisions violate the Supremacy Clause by attempting to directly regulate federal operations. The district court declined to enjoin enforcement of Section 10 against federal agencies and officers, reasoning that the United States had not shown that the state’s identification requirement interfered with or controlled essential federal law enforcement operations. On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s refusal to grant preliminary injunctive relief. The Ninth Circuit held that Section 10 of the No Vigilantes Act attempts to directly regulate the federal government in its performance of governmental functions, which the Supremacy Clause forbids. The court explained that states may not directly regulate the conduct of the federal government or its officers, regardless of whether the regulation is minimal or aligns with state requirements for state officers. Concluding that the United States is likely to succeed on the merits of its claim, and that the remaining preliminary injunction factors favored the United States, the Ninth Circuit granted an injunction pending appeal, enjoining California from enforcing Section 10 against federal agencies and officers. View "USA V. STATE OF CALIFORNIA" on Justia Law

J. R. V. VENTURA UNIFIED SCHOOL DISTRICT

2026-04-22T09:06:00-08:00

A child attended the Ventura Unified School District from 2012 to 2021. During this time, the district performed several psychoeducational assessments, identifying the child as having a specific learning disability but failing to assess for autism. The child’s parents, aware of his persistent academic and behavioral struggles, repeatedly collaborated with the district, sought private assessments, and requested additional services, which were denied. The child was ultimately diagnosed with autism in 2021, after which the parents initiated legal action seeking remedies for allegedly inadequate education dating back to 2012. After the parents filed a due process complaint in 2021, an Administrative Law Judge concluded that claims for services before April 8, 2019, were time-barred under the Individuals with Disabilities Education Act’s (IDEA) two-year statute of limitations, finding the parents knew or should have known of the district’s failure to assess for autism and of the child’s inadequate education before that date. The ALJ awarded relief only for the period after April 8, 2019. The parents then sought further review in the United States District Court for the Central District of California, which reversed the ALJ. The district court held that the statute of limitations did not begin until the autism diagnosis in 2021, reasoning the parents lacked the requisite knowledge to challenge the district’s actions earlier. The court also found both statutory exceptions to the limitations period applied and awarded remedies for the 2012–2019 period. The United States Court of Appeals for the Ninth Circuit reversed the district court. The court held that the IDEA’s two-year statute of limitations begins when parents knew or should have known both of the district’s action or inaction and that their child was being denied a free appropriate public education. It concluded that the parents’ claims for pre-2019 educational services were untimely. The appellate court vacated the district court’s remedial orders and remanded for further proceedings regarding attorneys’ fees. View "J. R. V. VENTURA UNIFIED SCHOOL DISTRICT" on Justia Law

MOVING OXNARD FORWARD, INC. V. LOPEZ

2026-04-22T08:31:11-08:00

A nonprofit political advocacy organization challenged a set of municipal campaign finance rules adopted by a California city after a history of local government scandals involving city officials and local business interests. The ballot measure, approved by 82% of city voters, imposed per candidate contribution limits for individuals and political action committees, as well as aggregate contribution limits, for city elections. The measure was adopted in response to a series of incidents where city officials accepted valuable gifts or travel from local business figures and subsequently took official actions arguably benefiting those providers. A district attorney’s investigation and report, media coverage, and a resident survey indicating strong public demand for accountability preceded the measure. After the measure took effect, the advocacy organization sued in the United States District Court for the Central District of California, arguing that the per candidate and aggregate contribution limits violated the First and Fourteenth Amendments. Both sides filed for summary judgment. The district court granted summary judgment for the city, holding that the per candidate limits were justified by a sufficiently important governmental interest and closely drawn to that interest, and that the aggregate limits did not impermissibly discriminate against candidates who also supported ballot measures. The court also upheld a related gift ban, but the plaintiffs did not appeal that aspect. The United States Court of Appeals for the Ninth Circuit, sitting en banc, affirmed the district court’s decision. The Ninth Circuit held that the city established an important governmental interest in preventing quid pro quo corruption or its appearance, and that the contribution limits were closely drawn, not unconstitutionally low, and comparable to other cities’ limits. The court further found that the aggregate limits were constitutional, as they did not apply to ballot measure committees. Thus, the city’s campaign finance limits were upheld. View "MOVING OXNARD FORWARD, INC. V. LOPEZ" on Justia Law

USA V. BOLANDIAN

2026-04-21T08:31:43-08:00

Shahriyar Bolandian was convicted of insider trading based on allegations that he traded on nonpublic information regarding the mergers of two companies, information allegedly obtained from a friend, Ashish Aggarwal, who worked at J.P. Morgan. Bolandian executed trades in the stocks of PLX Technologies and ExactTarget before their respective acquisitions, ultimately earning substantial profits. These trades occurred while Aggarwal, though not assigned to the deals, worked in the relevant banking group. The case revolved around whether Aggarwal had improperly shared confidential information, and whether Bolandian knowingly traded on it. Initially, the United States District Court for the Central District of California severed Aggarwal’s trial from that of Bolandian and another co-defendant, Sadigh, due to the risk of antagonistic defenses. Aggarwal was ultimately acquitted by a jury. Afterward, a superseding indictment charged only Bolandian and Sadigh, and eventually Bolandian alone proceeded to trial. During Bolandian’s trial, a juror (Juror No. 6) expressed uncertainty about his ability to be impartial due to a family connection to J.P. Morgan. The district court questioned Juror No. 6 briefly, but allowed him to remain on the jury after both parties did not object. The United States Court of Appeals for the Ninth Circuit reviewed Bolandian’s conviction and focused on the issue of juror bias. The court held that the district court failed in its independent duty to investigate credible allegations of juror bias after Juror No. 6 expressed doubt about his impartiality. The panel concluded that defense counsel’s agreement to keep Juror No. 6 did not waive Bolandian’s right to challenge for bias, as a proper investigation is a prerequisite to waiver. The Ninth Circuit found plain error, vacated Bolandian’s conviction, and remanded for a new trial. View "USA V. BOLANDIAN" on Justia Law

MCAULIFFE V. ROBINSON HELICOPTER COMPANY

2026-04-21T08:31:41-08:00

The case concerns a fatal helicopter crash during a sightseeing tour in Hawaii, resulting in the deaths of all aboard, including the plaintiffs’ daughter. The helicopter, manufactured by Robinson Helicopter Company in 2000, had its main rotor hub and blades replaced with new, identical parts from Robinson in December 2018, which was over eighteen years after the helicopter’s initial delivery. The plaintiffs alleged that defects in the replaced rotor hub and blades caused the crash, and brought claims for negligence, strict products liability, and failure to warn. The United States District Court for the District of Hawaii heard the case first. Robinson invoked the General Aviation Revitalization Act of 1994 (GARA), which generally bars actions against manufacturers eighteen years after delivery of the aircraft. The plaintiffs argued for exceptions under GARA’s “rolling provision”—which restarts the repose period for newly replaced parts—and the “fraud exception”—which removes the bar if the manufacturer concealed or misrepresented material information to the FAA. The district court granted summary judgment for Robinson, holding that the rolling provision did not apply because the replacement parts were not substantively altered from the originals, and that the plaintiffs failed to plead fraud with the necessary specificity. The court also denied the plaintiffs’ motion to further amend their complaint. On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court erred in requiring a “substantive alteration” for the rolling provision to apply, as GARA only requires that a new part replaces an old one. The Ninth Circuit reversed the grant of summary judgment in part and remanded for a new causation analysis regarding the replaced parts. However, the court affirmed the lower court’s determinations that the plaintiffs failed to meet the requirements for the fraud exception and that denying leave to amend was not an abuse of discretion. View "MCAULIFFE V. ROBINSON HELICOPTER COMPANY" on Justia Law

BROWN V. SALCIDO

2026-04-20T09:03:20-08:00

Several individuals alleged that Google collected and misused the private browsing data of Chrome users who utilized Incognito mode, despite Google’s representations about the privacy of this feature. In June 2020, five plaintiffs brought a putative class action on behalf of these users, seeking both injunctive relief and damages. After extensive discovery, the United States District Court for the Northern District of California certified a class for injunctive relief but denied certification for a damages class, finding the plaintiffs had not shown that common issues predominated over individual ones. Following the denial of damages class certification, the named plaintiffs sought review in the United States Court of Appeals for the Ninth Circuit under Rule 23(f), but the petition was denied. The case proceeded, and as trial approached, the parties settled: Google agreed to change its policies, the named plaintiffs would arbitrate their individual damages claims, and they waived their rights to appeal the denial of damages class certification. The settlement explicitly stated that absent class members were not releasing damages claims or appellate rights. Several months after the settlement, a group of 185 Chrome users, referred to as the Salcido plaintiffs, moved to intervene to preserve absent class members’ appellate rights regarding damages. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of the intervention motion. The Ninth Circuit held that the district court did not abuse its discretion in finding the intervention motion untimely. Applying the circuit’s traditional three-part test for intervention—considering the stage of the proceedings, prejudice to other parties, and the reason for and length of delay—the court found that intervention at this late stage would prejudice the existing parties, that the delay was unjustified, and that the timing weighed against intervention. The denial of the motion to intervene was therefore affirmed. View "BROWN V. SALCIDO" on Justia Law

PANELLI V. TARGET CORPORATION

2026-04-17T08:01:05-08:00

A consumer purchased a set of bed sheets from a major retailer, choosing a more expensive option because the packaging stated the sheets were made of “100% cotton” and had an “800 Thread Count.” After using the sheets, he believed the quality did not match the advertised thread count. He later had the sheets tested by an expert, who determined the actual thread count was much lower. The consumer alleged that it is physically impossible for 100% cotton fabric to reach the advertised thread counts and claimed that the retailer’s labeling was false and misleading. The consumer initially brought a class action in California state court, alleging violations of California’s Unfair Competition Law and Consumer Legal Remedies Act. The retailer removed the suit to the United States District Court for the Southern District of California. The retailer moved to dismiss the complaint, arguing that the consumer failed to adequately plead his claims and that the impossibility of the claimed thread count meant no reasonable consumer would be misled. The district court agreed and dismissed the case with prejudice, relying on the Ninth Circuit’s decision in Moore v. Trader Joe’s Co., interpreting it to mean that literally impossible claims cannot deceive reasonable consumers as a matter of law. The United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. The court held that the district court erred in its interpretation of Moore. The appellate court clarified that claims of literal falsity are actionable under California consumer protection laws and that even physically impossible claims may deceive reasonable consumers. The court reversed the district court’s dismissal and remanded the case for further proceedings, holding that the consumer’s allegations were sufficient to survive a motion to dismiss. View "PANELLI V. TARGET CORPORATION" on Justia Law

BROWN V. THE BRITA PRODUCTS COMPANY

2026-04-16T09:05:35-08:00

A consumer purchased a Brita water filter product, alleging that the product’s labeling and packaging led him to believe it would remove or reduce hazardous contaminants in tap water to below laboratory-detectable levels. He contended that the packaging conveyed the impression that the product would eliminate a broad range of harmful substances, but did not clearly or conspicuously state that it would not do so. The consumer claimed that he would not have purchased the product or would have paid less if he had known its actual capabilities, and asserted that reasonable consumers would have similar expectations based on the labeling. After Brita removed the lawsuit to the United States District Court for the Central District of California, the district court dismissed the complaint in its entirety without leave to amend. The district court found that the plaintiff’s claims for affirmative misrepresentation and material omission failed, applying the reasonable consumer standard and concluding that no reasonable consumer would interpret Brita’s packaging as promising removal of all hazardous contaminants to below lab-detectable limits. The district court also found the plaintiff lacked standing for certain statutory claims and determined that amendment would be futile. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s dismissal and affirmed the decision. The appellate court held that no reasonable consumer would expect Brita’s water filter products to remove or reduce all hazardous contaminants to below laboratory-detectable levels, especially in light of Brita’s disclosures about the products’ capabilities and limitations. The court further held that the omission claim failed as a matter of law under the reasonable consumer standard. Finally, the appellate court concluded that the district court did not abuse its discretion by denying leave to amend, as amendment would not cure the defect. Judgment was affirmed. View "BROWN V. THE BRITA PRODUCTS COMPANY" on Justia Law

GONZALES V. BATTELLE ENERGY ALLIANCE, LLC

2026-04-16T09:05:35-08:00

Roman Gonzales worked as a Security Police Officer for a government contractor managing a nuclear facility. He had a chronic back injury, for which he took prescription opiates. Battelle Energy Alliance, the contractor, was aware of his medical condition and medication. For several years, Gonzales performed his duties without incident, including after the Department of Energy began requiring more stringent security and medical certifications for such officers. Despite no change in his medication regimen or job performance, Battelle, after a change in medical staff and updated drug testing protocols, revoked Gonzales’s fitness-for-duty certification and subsequently terminated his employment. Gonzales then learned that management had informed coworkers he was being dismissed as an “opioid abuser,” which he reported to human resources. Gonzales filed suit in the United States District Court for the District of Idaho, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA). After a five-day trial, the jury found in his favor on claims of retaliation and “regarded as” disability discrimination. Battelle moved for judgment as a matter of law, arguing that decisions involving the revocation of security-related certifications, such as the one at issue, were not subject to judicial review because such decisions are reserved for federal agencies under national security regulations. The district court denied this motion. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The court held that revocation of Gonzales’s fitness-for-duty certification under 10 C.F.R. § 1046 was subject to judicial review because it involved medical and physical standards, not predictive national security determinations or security clearance decisions reserved to the Department of Energy. The court distinguished between non-justiciable security clearance decisions and fitness-for-duty certifications, ensuring ADA protections remain enforceable. View "GONZALES V. BATTELLE ENERGY ALLIANCE, LLC" on Justia Law

USA V. GONZALEZ-REYES

2026-04-15T08:01:39-08:00

A man was convicted in California of forcible rape, false imprisonment by menace or violence, and corporal injury on a cohabitant after he assaulted his girlfriend. Following his prison sentence, as a Mexican national who had entered the United States unlawfully, he was removed from the United States through an expedited process based on his conviction for rape, which was deemed an aggravated felony under federal immigration law. Days later, he illegally reentered the country and was arrested near the border. He was then charged with illegal reentry under 8 U.S.C. § 1326. In the United States District Court for the Southern District of California, he moved to dismiss the indictment, arguing that his state rape conviction did not qualify as an aggravated felony under the Immigration and Nationality Act, and thus his removal had been improper. The district court denied his motion. He then entered a conditional guilty plea, preserving his right to appeal the denial of his motion to dismiss. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court assumed for the sake of argument that the defendant met the statutory requirements of exhaustion of administrative remedies and deprivation of judicial review. However, it held that he failed to show that his removal was “fundamentally unfair” under 8 U.S.C. § 1326(d)(3). The court concluded that the California rape statute under which he was convicted was a categorical match to the generic federal definition of rape, which includes rape by non-physical duress. Therefore, his conviction was properly considered an aggravated felony, making his expedited removal lawful. The Ninth Circuit affirmed the district court’s denial of the motion to dismiss the indictment. View "USA V. GONZALEZ-REYES" on Justia Law

USA V. WILLIAMS

2026-04-13T08:01:27-08:00

Koby Don Williams, a supervisor with U.S. Immigration and Customs Enforcement, was charged with attempted online enticement of a minor after engaging in an undercover operation where he believed he was communicating with a thirteen-year-old girl named “Rebecca.” In reality, “Rebecca” was a persona created by law enforcement. Williams exchanged nearly 100 texts and several phone calls, during which “Rebecca” repeatedly stated her age. Williams negotiated sexual acts and payment, offered to travel with “Rebecca,” and ultimately arranged a meeting, bringing cash, alcohol, and generic Viagra. When arrested, Williams claimed he was conducting a human trafficking investigation. The United States District Court for the Eastern District of Washington presided over Williams’s trial. Williams’s primary defense was that he never believed “Rebecca” was a minor, asserting that he thought he was communicating with an adult. He filed pretrial motions to suppress or authenticate the decoy advertisement and, after conviction, moved for acquittal and a new trial, arguing insufficient evidence and statutory misinterpretation. The district court denied these motions. At sentencing, the court imposed a two-level obstruction-of-justice enhancement under the Sentencing Guidelines, based on Williams’s alleged perjury, without making specific factual findings. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that sufficient evidence supported the conviction for attempted enticement of a minor under 18 U.S.C. § 2422(b), rejecting Williams’s argument that the statute required proof he attempted to “transform or overcome the will” of a minor. The Ninth Circuit also found no plain error in the government’s failure to produce the original decoy advertisement. However, the court vacated Williams’s sentence, concluding the district court erred by not making explicit findings required to support the obstruction-of-justice enhancement, and remanded for resentencing. The conviction was affirmed. View "USA V. WILLIAMS" on Justia Law

NIA V. BANK OF AMERICA, N.A.

2026-04-13T08:01:26-08:00

An Iranian citizen, living in the United States, held a credit card account with a large financial institution. Due to United States sanctions against Iran, federal regulations prohibit U.S. banks from providing services to accounts of individuals ordinarily resident in Iran, unless those individuals are not located in Iran. The bank had a compliance policy requiring account holders from such sanctioned countries to regularly provide documents showing they were not residing in those countries. The plaintiff, subject to this policy, submitted various documents as proof of U.S. residency. After the bank mistakenly treated one of his residency documents as temporary rather than permanent, it closed his account when he failed to submit additional documentation. The plaintiff sued in state court, alleging violations of federal and state anti-discrimination and consumer protection statutes, including 42 U.S.C. § 1981, the Equal Credit Opportunity Act, the California Unruh Civil Rights Act, and the California Unfair Competition Law. The defendant bank removed the case to the United States District Court for the Southern District of California. The district court granted summary judgment for the bank on all claims except for an ECOA notice claim and a related UCL claim, both of which the plaintiff later voluntarily dismissed. The plaintiff then appealed. The United States Court of Appeals for the Ninth Circuit held that the International Emergency Economic Powers Act’s liability shield provision immunizes the bank from liability for good faith actions taken in connection with compliance with sanctions regulations, even if such actions are not strictly compelled by the regulations. The court found that the bank’s policy was consistent with federal guidance and that the plaintiff failed to show a genuine dispute of material fact regarding the bank’s good faith. The Ninth Circuit affirmed the district court’s judgment in favor of the bank. View "NIA V. BANK OF AMERICA, N.A." on Justia Law

G.B. V. ENVIRONMENTAL PROTECTION AGENCY

2026-04-09T08:31:15-08:00

A group of eighteen minors residing in California filed a lawsuit against the U.S. Environmental Protection Agency (EPA) and other federal officials, claiming that the government’s policy of discounting future costs and benefits in cost-benefit analyses for greenhouse gas (GHG) regulations discriminates against children. The plaintiffs alleged this practice favors present-day consumption, benefiting adults over minors, and leads to under-regulation of GHG emissions. They argued this under-regulation contributes to climate change, which, in turn, causes them various harms including property damage, health issues, and psychological distress. The case was first heard in the United States District Court for the Central District of California. That court dismissed the action, ruling that the plaintiffs lacked Article III standing. The court found that the plaintiffs’ claims did not establish a cognizable injury-in-fact, that the alleged environmental harms were not fairly traceable to the government’s discounting policies, and that the requested declaratory relief would not redress their injuries. The district court allowed the plaintiffs one opportunity to amend their complaint, but after the plaintiffs did so, the court again dismissed the case and denied further leave to amend, finding further amendment would be futile. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the plaintiffs failed to allege a viable injury to their equal protection rights, as the government’s discounting policies were not shown to be motivated by discriminatory intent toward children. The court also found the alleged environmental harms too attenuated and speculative to be fairly traceable to the challenged policies. Additionally, circuit precedent foreclosed the requested declaratory relief, as it would not redress the plaintiffs’ injuries. The Ninth Circuit concluded that denying further leave to amend was not an abuse of discretion. View "G.B. V. ENVIRONMENTAL PROTECTION AGENCY" on Justia Law

RAMIREZ V. THORNELL

2026-04-09T08:01:15-08:00

The case concerns a man convicted of the 1989 murders of his girlfriend and her daughter in Arizona. He was found guilty by a jury and subsequently sentenced to death by a judge. The sentencing judge identified multiple aggravating factors, including the especially cruel nature of the crimes, multiple victims, and prior violent felonies. The judge also found statutory and non-statutory mitigating factors, such as the defendant’s impaired capacity, troubled childhood, and psychological issues. After his conviction and sentencing were affirmed on direct appeal by the Arizona Supreme Court, the defendant sought postconviction relief in state court through three separate petitions. His first petition did not raise an ineffective assistance of counsel (IAC) claim and was handled by counsel later conceded to be ineffective. A second petition, raising the IAC claim, was denied as untimely. A third petition argued he was intellectually disabled and therefore ineligible for execution, but that claim was rejected after an evidentiary hearing. In federal court, the petitioner’s IAC claim was initially deemed procedurally defaulted by the United States District Court for the District of Arizona. Subsequent Supreme Court and Ninth Circuit decisions, including Martinez v. Ryan, allowed for the possibility that ineffective postconviction counsel could excuse such defaults. The Ninth Circuit originally remanded for an evidentiary hearing, but the United States Supreme Court reversed, holding that federal courts may not expand the state court record based on ineffective state postconviction counsel. On remand, the United States Court of Appeals for the Ninth Circuit considered only evidence properly submitted in state court under procedural rules. The Ninth Circuit found the petitioner demonstrated “cause” to excuse the procedural default but failed to show “prejudice,” as his underlying IAC claim was not “substantial.” Although counsel’s performance was deficient, the new mitigating evidence was unlikely to have changed the sentencing outcome, given the weight of aggravating factors and Arizona precedent. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "RAMIREZ V. THORNELL" on Justia Law

BROWN LOPEZ V. USA

2026-04-08T10:06:22-08:00

A group of environmental organizations, Native tribes, and individual plaintiffs sought to prevent a land exchange in Southeast Arizona’s Tonto National Forest, mandated by the Southeast Arizona Land Exchange and Conservation Act. This exchange would transfer nearly 2,500 acres of federal land, including Oak Flat—a site of religious significance to the Apache—and a large copper deposit to Resolution Copper Mining LLC. In return, the company would provide over 5,000 acres of equally appraised land to the federal government. Plaintiffs raised concerns under several statutes, including the Land Exchange Act, the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), the Religious Freedom Restoration Act (RFRA), and the Free Exercise Clause, alleging procedural and substantive flaws in the exchange. The United States District Court for the District of Arizona denied motions for preliminary injunctions, finding that plaintiffs failed to show likely success or serious questions on the merits of their claims relating to appraisal, NEPA compliance, tribal consultation, and religious liberty. In a related case, Apache Stronghold v. United States, the district court’s denial of an injunction on religious liberty grounds was affirmed by the Ninth Circuit and not disturbed by the Supreme Court. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a preliminary injunction. The court held that plaintiffs had Article III standing and that their NEPA claims were justiciable as “final agency action.” However, it concluded that plaintiffs were not likely to succeed on the merits of their appraisal, NEPA, consultation, or religious liberty claims. The court further determined that existing precedent foreclosed the RFRA and Free Exercise arguments. The court did not address other injunction factors and dissolved the administrative stay. View "BROWN LOPEZ V. USA" on Justia Law

BROTHERS MARKET LLC NO. 2 V. USA

2026-04-08T08:32:20-08:00

A small convenience store in downtown Los Angeles, owned by an individual, participated in the Supplemental Nutrition Assistance Program (SNAP) and served many customers who used electronic benefit transfer (EBT) cards. In early 2022, the Food and Nutrition Service of the United States Department of Agriculture detected suspicious patterns in the store’s SNAP transactions. Over six months, the store processed hundreds of unusually large transactions, nearly 200 transactions that depleted a household’s monthly benefits in one day, numerous rapid consecutive transactions by the same household, and many transactions for the same dollar amount. Following a physical inspection and review of these patterns, the Agency charged the store with trafficking in SNAP benefits, meaning exchanging benefits for cash or non-eligible goods. After receiving a charge letter and providing a response that generally denied wrongdoing and offered explanations for customer behavior, the store was permanently disqualified from SNAP by the Agency. The owner and the store sought administrative review and submitted additional documents, including affidavits and receipts, but the Agency upheld its decision. The plaintiffs then filed for judicial review in the United States District Court for the Central District of California. The government moved for summary judgment, and the plaintiffs relied on much of the same evidence previously submitted. The district court granted summary judgment for the government, finding that the plaintiffs failed to raise a genuine dispute of material fact as to whether trafficking had occurred. On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the government’s evidence established suspicious transaction patterns supporting an inference of SNAP trafficking and that the plaintiffs failed to provide sufficient evidence to create a genuine dispute as to the legitimacy of the flagged transactions. The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of the government. View "BROTHERS MARKET LLC NO. 2 V. USA" on Justia Law

ENG V. ENVIRONMENTAL PROTECTION AGENCY

2026-04-08T08:32:20-08:00

A resident living near a Los Angeles refinery operated by Ultramar Inc., a subsidiary of Valero Energy Corp., challenged the renewal of the refinery’s operating permit. The facility, located in Wilmington, is subject to Title V of the Clean Air Act, which requires certain air polluters to obtain operating permits. The resident argued that the permit should include additional conditions to address the potential for a catastrophic release of hydrogen fluoride or modified hydrofluoric acid. He pointed to alleged deficiencies in the refinery’s Risk Management Plan (RMP), Emergency Response Plan, Emergency Response Manual, and other documents, claiming these left the refinery unprepared for such an event. The South Coast Air Quality Management District (SCAQMD), acting as the Title V permitting authority, solicited public comments before issuing the permit. The petitioner submitted objections during this process, but SCAQMD rejected them and issued the permit. The petitioner then filed an administrative petition with the Administrator of the United States Environmental Protection Agency (EPA), asking the EPA to object to the permit. The EPA Administrator denied the petition, concluding that issues related to risk management plans and accidental release prevention fall under a separate regulatory program, not the Title V permitting process. The Administrator also found that the requirements referenced by the petitioner were not “applicable requirements” of the Clean Air Act for Title V purposes. The United States Court of Appeals for the Ninth Circuit reviewed the EPA’s decision. The court held that the Administrator’s denial was not arbitrary, capricious, or contrary to law. It concluded that the petitioner failed to show that additional permit conditions were required to ensure compliance with the Clean Air Act’s risk management requirements. The court also found that the petitioner’s arguments based on state law did not qualify as applicable federal requirements. Accordingly, the Ninth Circuit denied the petition for review. View "ENG V. ENVIRONMENTAL PROTECTION AGENCY" on Justia Law

SANTANA-GONZALEZ V. BONDI

2026-04-08T08:01:10-08:00

A Mexican citizen entered the United States unlawfully several times between 2014 and 2015. After being denied entry and returning to Mexico multiple times, he eventually made a claim for protection, asserting fears of harm from a vigilante group in Mexico called the Defensores of Guerrero, who he said pressured him to join them or a rival cartel. He also cited threats following police contact and discrimination based on his sexual orientation, though he admitted he had not been physically harmed due to his sexuality. He expressed concerns about the safety of relocation within Mexico and referenced crimes against his father by unidentified individuals. The individual’s parents and siblings continued to live in Mexico without incident. An Immigration Judge (IJ) denied his applications for asylum, withholding of removal, and protection under the Convention Against Torture, finding no nexus between the alleged harm and a protected ground, insufficient evidence of past persecution, the reasonableness of internal relocation, and lack of likelihood of torture by or with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing that the individual failed to establish the necessary connections and that the claimed harms did not rise to the level of persecution. The United States Court of Appeals for the Ninth Circuit reviewed the BIA’s decision. The court held that the petitioner had forfeited all arguments on the merits of his immigration claims by not raising them in his opening brief and had also failed to exhaust his procedural due process arguments before the BIA. The court denied the petition for review, ruling that none of the petitioner’s arguments warranted relief, and it would not reach the unexhausted due process claims. View "SANTANA-GONZALEZ V. BONDI" on Justia Law

USA V. VERHONICH

2026-04-07T08:31:14-08:00

The case concerns an incident that occurred at Lake Mead, where Bryce Tyrone Verhonich operated a jet ski with a passenger, Lily Hatcher, in the early morning hours. After taking a detour to view the sunrise, both Verhonich and Hatcher fell into the water under rough conditions. Verhonich, who was not wearing a life jacket or engine cut-off lanyard, was rescued, but Hatcher drowned. Subsequent investigation revealed that neither individual was wearing a personal flotation device and the engine cut-off switch lanyard was not attached to Verhonich. Surveillance and body camera footage confirmed these facts. Hatcher’s body was later recovered, and an autopsy found drowning as the cause of death, with drugs as contributing factors. The case was first tried before a United States magistrate judge, who found Verhonich guilty of negligent operation of a vessel, failure to wear a personal flotation device, and failure to attach the engine cut-off switch lanyard—all in violation of National Park Service regulations. The magistrate judge sentenced him to six months in custody and two years of probation. Verhonich appealed to the United States District Court for the District of Nevada, arguing improper admission of evidence, insufficient evidence for conviction on negligent operation, and sentencing error. The district court affirmed the convictions and sentence. On further appeal, the United States Court of Appeals for the Ninth Circuit held that failure to wear a life jacket and failure to attach a safety lanyard may both be considered in determining negligent operation under 36 C.F.R. § 3.8(b)(8). The court found sufficient evidence to support Verhonich’s conviction, determined that evidentiary objections did not survive plain error review, and upheld the sentence as reasonable. The Ninth Circuit affirmed the district court’s judgment. View "USA V. VERHONICH" on Justia Law

DOE V. BONTA

2026-04-07T08:01:11-08:00

This case involves several dialysis providers, a nonprofit organization, and individual patients challenging a California law (AB 290) aimed at regulating relationships between dialysis providers and nonprofits that assist patients with health insurance premiums. The law was enacted due to concerns that providers were donating to nonprofits to help keep patients on private insurance, which led to higher reimbursements for providers compared to public insurance. Key provisions of the law included capping provider reimbursements if they had a financial relationship with a nonprofit offering patient assistance, requiring disclosure of patients receiving such assistance, restricting nonprofits from conditioning assistance on patient treatment choices, mandating disclosure to patients of all insurance options, and a safe harbor for seeking federal advisory opinions. The United States District Court for the Central District of California granted in part and denied in part motions for summary judgment. It upheld the constitutionality of the reimbursement cap, coverage disclosure requirement, and safe harbor provision, but found the anti-steering, patient disclosure, and financial assistance restriction provisions unconstitutional. The district court also ruled that the unconstitutional parts were severable from the remainder of the statute and rejected claims that federal law preempted the state law. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the reimbursement cap, patient disclosure requirement, and financial assistance restriction violated the First Amendment because they burdened the rights of expressive association and were not narrowly tailored to serve the state’s interests. The court found the coverage disclosure requirement constitutional under the standard for compelled commercial speech, as it required only factual, uncontroversial information reasonably related to a state interest. However, it concluded that the unconstitutional provisions were not severable from the coverage disclosure requirement. The court also held challenges to the safe harbor provision moot. The court affirmed in part, reversed in part, and each party was ordered to bear its own costs. View "DOE V. BONTA" on Justia Law

OLSON V. FCA US, LLC

2026-04-07T08:01:11-08:00

The plaintiff entered into a lease agreement with a car dealership to lease a Jeep Grand Cherokee. The lease included an arbitration agreement containing a delegation clause, which specified that disputes about the scope of the arbitration agreement would be decided in arbitration. Later, the plaintiff filed a federal class action lawsuit against the vehicle’s manufacturer, alleging defects in the headrest. The manufacturer, however, was not a party to the lease agreement and did not claim to be an employee, agent, successor, or assign of the dealership. After the lawsuit was filed in the United States District Court for the Eastern District of California, the manufacturer moved to compel arbitration, arguing that the delegation clause required an arbitrator—not the court—to decide whether the manufacturer could enforce the arbitration agreement. In the alternative, the manufacturer asserted that either the plain language of the agreement or the doctrine of equitable estoppel entitled it to compel arbitration. The district court denied the motion, finding that the manufacturer could not enforce the arbitration agreement because it was not a party to the contract and none of the exceptions allowing enforcement by a non-signatory applied. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s denial of the motion to compel arbitration. The appellate court held that, absent a relevant exception, a non-party to an arbitration agreement cannot enforce the agreement’s terms against a signatory. It found that the language of the arbitration agreement did not cover disputes with the manufacturer, and under California law, the manufacturer could not use equitable estoppel to compel arbitration because the plaintiff’s claims were not founded in or intertwined with the lease agreement. The court’s disposition was to affirm the district court’s order. View "OLSON V. FCA US, LLC" on Justia Law

THROWER V. ACADEMY MORTGAGE CORPORATION

2026-04-06T08:31:12-08:00

A former mortgage underwriter sued her employer under the False Claims Act, alleging that the company submitted false certifications in a federal mortgage insurance program. The government declined to intervene and unsuccessfully moved to dismiss the case. After years of litigation, the parties reached a settlement: the employer agreed to pay $38.5 million, with a portion going to the plaintiff and the remainder to the United States Treasury. The settlement specifically excluded the plaintiff’s claims for attorneys’ fees, expenses, and costs, leaving them unresolved. The United States District Court for the Northern District of California approved the settlement in January 2023, dismissing the substantive claims but expressly keeping the attorneys’ fees issue pending. Months of disputes ensued over the amount of attorneys’ fees. In May 2024, the district court awarded the plaintiff over $8.5 million in attorneys’ fees and approximately $89,000 in expenses. The plaintiff argued that postjudgment interest on these amounts should accrue from the date of the settlement approval, since her entitlement to fees was established then. The district court disagreed, holding that interest should only begin to accrue from the date the fees were actually awarded. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that postjudgment interest under 28 U.S.C. § 1961(a) accrues only from the entry of a “money judgment,” which requires both identification of the parties and a definite, ascertainable amount owed. Because the district court’s earlier order approving the settlement did not specify the amount of attorneys’ fees, it was not a “money judgment.” Therefore, interest begins accruing only from the order that set the fee amount. The Ninth Circuit affirmed the district court’s decision. View "THROWER V. ACADEMY MORTGAGE CORPORATION" on Justia Law

THROWER V. ACADEMY MORTGAGE CORPORATION

2026-04-06T08:31:12-08:00

A former employee filed a qui tam action under the False Claims Act against her former employer, alleging that the company falsely certified compliance with federal mortgage program requirements. The Department of Housing and Urban Development would be responsible for defaulted loans under this program. The relator’s attorneys conducted an extensive investigation, including interviewing former employees, after the government declined to intervene and later sought to dismiss the action. Despite these challenges, the relator’s attorneys successfully opposed the motions to dismiss, and the case proceeded. The litigation ultimately resulted in a settlement exceeding $38 million, with the relator and her attorneys receiving a portion of the recovery. The United States District Court for the Northern District of California calculated attorneys’ fees using the lodestar method, finding the hourly rates and hours reasonable, and arrived at a lodestar amount of approximately $4.37 million for the relator’s main counsel. The district court then awarded a 1.75 multiplier, increasing the fee award to over $8.5 million. The court justified the enhancement by citing the “exceptional result” achieved—surviving dismissal against both the government and the employer—and the attorneys’ investigative efforts, but did not provide a detailed rationale for choosing the 1.75 figure. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the district court abused its discretion by awarding a multiplier above the lodestar because the factors cited for the enhancement—exceptional results and investigative work—were already reflected in the lodestar calculation. The Ninth Circuit further found that the district court failed to provide a sufficiently reasoned explanation for selecting a 1.75 multiplier. The court reversed the enhanced fee award and remanded for further proceedings. View "THROWER V. ACADEMY MORTGAGE CORPORATION" on Justia Law

ESKILIAN V. BONDI

2026-04-02T08:01:06-08:00

A woman born in Soviet Armenia immigrated to the United States as a child and was later convicted of grand theft in California. In 2011, she was ordered removed based on this conviction. However, because Armenia did not accept individuals born during the Soviet era, she was considered “stateless” and not deported. She lived in the United States under supervision, checking in annually with immigration authorities. In 2018, she was informed that Armenia had begun accepting such individuals, which placed her at immediate risk of removal. She promptly retained counsel, who identified grounds to vacate her conviction due to a procedural defect, and the conviction was vacated in May 2019. Following the vacatur, she filed a motion to reopen her removal proceedings, but the Immigration Judge denied it, finding she had not explained why she waited over two years after the relevant California statute became effective to seek vacatur. She then filed a second motion to reopen, arguing ineffective assistance of counsel because her counsel in the first motion failed to present facts or arguments about her diligence. The Immigration Judge denied the second motion as number-barred, and the Board of Immigration Appeals (BIA) dismissed her appeal, finding she had not demonstrated due diligence and thus was not entitled to equitable tolling. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the BIA applied the wrong standard in assessing diligence for stateless individuals. The Ninth Circuit concluded that it is reasonable for someone in her position to begin challenging removability only upon learning they are at risk of removal. The court found she acted with due diligence after learning of her removability and that the BIA abused its discretion in finding otherwise. The court granted her petition for review, vacated the BIA’s decision, and remanded for further proceedings. View "ESKILIAN V. BONDI" on Justia Law

LOS ANGELES PRESS CLUB V. NOEM

2026-04-01T08:31:10-08:00

During the summer of 2025, protests erupted in Southern California in response to federal immigration raids. Protesters, legal observers, and journalists alleged that officers of the Department of Homeland Security (DHS), including agents from Immigration and Customs Enforcement, the Federal Protective Services, and Customs and Border Protection, used crowd control weapons indiscriminately against them. Multiple individuals, including members of the press and protesters, suffered significant physical injuries during these events, even when they were complying with police orders or were not near disruptive protest activity. Several individual journalists, legal observers, protesters, and two press organizations filed suit in the United States District Court for the Central District of California. They alleged violations of their First Amendment rights, specifically the right to be free from retaliation for engaging in protected activities and the right of public access to protests. The district court issued a preliminary injunction to protect the rights of protesters, journalists, and legal observers, finding that the defendants’ conduct chilled First Amendment activity. The government appealed, arguing that the injunction was overly broad and legally unsound. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit held that the plaintiffs were likely to succeed on their First Amendment retaliation claims, that both individual and organizational plaintiffs had standing, and that the other requirements for a preliminary injunction were met. However, the court found that the scope of the injunction was overbroad because it extended relief to non-parties and included provisions not narrowly tailored to the specific harms alleged. The Ninth Circuit affirmed the district court’s decision to issue a preliminary injunction but vacated and remanded the case for the district court to craft a narrower injunction consistent with its opinion. View "LOS ANGELES PRESS CLUB V. NOEM" on Justia Law

RUIZ V. BONDI

2026-04-01T08:01:06-08:00

A citizen of Mexico was the beneficiary of an approved family-sponsored immigrant visa petition filed by his mother in 1992, which was approved in 1993. He did not apply for lawful permanent resident status at that time. In 2000, he was deemed inadmissible at the United States-Mexico border, ordered removed, and was actually removed. He reentered the United States without inspection shortly thereafter. In 2017, his wife filed a new immigrant visa petition on his behalf, which was approved, and he applied for adjustment of status. During a 2018 interview regarding that application, he admitted to being illegally present and previously removed, after which he was arrested and DHS began proceedings to reinstate his prior removal order. After the Department of Homeland Security reinstated his prior removal order, the petitioner sought review by the United States Court of Appeals for the Ninth Circuit. DHS identified a procedural error in the initial reinstatement (an unsigned section), canceled the order, and began the process again. At the second reinstatement proceeding, the petitioner was advised of his rights but declined to make a statement or sign the acknowledgment form. DHS reinstated the removal order, and he again appealed to the Ninth Circuit. The United States Court of Appeals for the Ninth Circuit denied the petition for review. The court held that it was not impermissibly retroactive to apply the Illegal Immigration Reform and Immigrant Responsibility Act of 1996’s reinstatement provision to the petitioner because he had not taken any affirmative steps to adjust his status before the law took effect. The court further held that, to obtain relief for a due process violation based on denial of a right to counsel in reinstatement proceedings, an alien must show prejudice, and the petitioner failed to establish such prejudice. The petition was denied. View "RUIZ V. BONDI" on Justia Law

O'DELL V. AYA HEALTHCARE SERVICES, INC.

2026-04-01T08:01:06-08:00

Former employees of a travel-nursing agency brought a putative class action against the agency, alleging wage-related violations. Each employee had signed an arbitration agreement with the agency that contained a delegation clause requiring an arbitrator—not a court—to decide on the validity of the agreement. Four initial plaintiffs had their disputes sent to arbitration: two arbitrators found the agreements valid, while two found them invalid due to unconscionable fee and venue provisions. After these initial arbitrations, the United States District Court for the Southern District of California confirmed three out of four arbitral awards. At this stage, an additional 255 employees joined the action as opt-in plaintiffs under the Fair Labor Standards Act. The agency moved to compel arbitration for these additional plaintiffs under their individual agreements. However, a different district judge raised the issue of whether non-mutual offensive collateral estoppel barred the enforcement of the arbitration agreements. After briefing, the district court denied the agency’s motion, concluding that the two arbitral awards finding the agreements invalid precluded arbitration for all 255 employees, effectively rendering their agreements unenforceable. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The Ninth Circuit held that the application of non-mutual offensive collateral estoppel to preclude the enforcement of arbitration agreements is incompatible with the Federal Arbitration Act (FAA). The court reasoned that such an approach undermined the principle of individualized arbitration and the parties’ consent, which are fundamental to the FAA. The Ninth Circuit concluded that the FAA does not permit using non-mutual offensive collateral estoppel to invalidate arbitration agreements and remanded the case for further proceedings. View "O'DELL V. AYA HEALTHCARE SERVICES, INC." on Justia Law

USA V. CASILDO

2026-03-31T08:01:09-08:00

The case concerns an individual convicted of two counts of possession with intent to distribute methamphetamine and one count of conspiracy to distribute a controlled substance, stemming from a 2018 indictment related to the sale of methamphetamine. At sentencing, the district court classified him as a career offender under the United States Sentencing Guidelines, based on two prior convictions: one federal conviction for distribution of cocaine and one Nevada state conviction for the sale of controlled substances under Nevada Revised Statute § 453.321(1)(a). This classification resulted in a higher sentencing range, and he ultimately received a sentence of 235 months, substantially longer than a similarly situated co-defendant. After his direct appeal was unsuccessful, he filed a pro se motion under 28 U.S.C. § 2255 in the United States District Court for the District of Idaho, arguing that his prior Nevada conviction was not a qualifying “controlled substance offense” for the purposes of the career offender enhancement. The district court held that this claim was procedurally barred because it was not raised on direct appeal, and alternatively found that the prior conviction did qualify as a predicate offense. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that there was cause and prejudice to excuse the procedural default, finding that his appellate counsel was ineffective for failing to challenge the career offender enhancement, and that this failure prejudiced the outcome. On the merits, the Ninth Circuit determined that the relevant Nevada statute is indivisible and overbroad, and therefore, his conviction under that statute cannot serve as a predicate offense for career offender status under the Guidelines. The court reversed the district court’s dismissal of the § 2255 motion and remanded for resentencing. View "USA V. CASILDO" on Justia Law

USA V. CHAVEZ-ECHEVERRIA

2026-03-25T08:01:11-08:00

The defendant pleaded guilty in 2024 to being a felon in possession of a firearm. At sentencing, the government sought an increased base offense level under the U.S. Sentencing Guidelines, which applies if the defendant has at least two prior felony convictions for a crime of violence. The defendant conceded that a previous conviction for third-degree assault in Oregon counted as one predicate crime of violence, but contested whether his 2021 Oregon conviction for attempted first-degree assault qualified as a second predicate. The United States District Court for the District of Oregon concluded that attempted first-degree assault under Oregon law does qualify as a crime of violence and increased the defendant’s base offense level accordingly. The court calculated a Guidelines range of 108 to 135 months and sentenced the defendant to 80 months’ imprisonment. The defendant appealed, arguing that the attempt statute in Oregon is broader than the federal definition of attempt and should not qualify under the “force clause” of the Sentencing Guidelines. The United States Court of Appeals for the Ninth Circuit reviewed the case. Applying its precedent, the court held that the “attempted use” of physical force, as required by the force clause in the Sentencing Guidelines, means taking a substantial step toward the use of physical force. Because Oregon law requires a substantial step toward causing serious physical injury for a conviction of attempted first-degree assault, the Ninth Circuit concluded that such a conviction qualifies as a crime of violence. The court rejected the argument that a narrower “probable desistance” test should apply and affirmed the sentence imposed by the district court. View "USA V. CHAVEZ-ECHEVERRIA" on Justia Law

USA V. DEPAPE

2026-03-25T08:01:11-08:00

After a jury trial, the defendant was convicted of attempting to kidnap a federal officer and assaulting a family member of a federal official. During sentencing in the United States District Court for the Northern District of California, the court heard arguments from counsel for both the defense and the government, but did not ask the defendant if he wished to speak personally before sentencing—a procedural requirement known as allocution, mandated by Federal Rule of Criminal Procedure 32. Shortly after imposing concurrent maximum sentences for both counts, the government realized the allocution right had been overlooked and promptly moved to reopen sentencing under Federal Rule of Criminal Procedure 35(a), which allows correction of “arithmetical, technical, or other clear error” within 14 days of sentencing. The district court granted the government’s motion over the defendant’s objection, vacated the original sentence, and set a new sentencing hearing. At the subsequent hearing, the defendant was allowed to address the court and allocute. The district court then reimposed the same sentences as before. On appeal, the United States Court of Appeals for the Ninth Circuit considered whether the district court had the authority to correct its failure to afford allocution by reopening sentencing under Rule 35(a). The Ninth Circuit held that the failure to allow a defendant the right to allocute under Rule 32 constitutes “other clear error” correctable under Rule 35(a). The court concluded that resentencing after a belated allocution is permissible under Rule 35(a), even if it requires the exercise of judicial discretion. The Ninth Circuit therefore affirmed the sentence imposed by the district court. View "USA V. DEPAPE" on Justia Law

STATE OF ALASKA V. NATIONAL MARINE FISHERIES SERVICE

2026-03-25T08:01:10-08:00

The case concerns the National Marine Fisheries Service’s (NMFS) designation of critical habitat in 2022 for two species of Arctic seals, following their listing as threatened under the Endangered Species Act (ESA) in 2012. The designated areas covered waters off Alaska’s north coast and were based on findings that those areas contained physical and biological features essential to the conservation of the seal species. Alaska opposed these designations, contending that they were too broad and provided minimal benefit, and requested that certain coastal areas be excluded due to economic impacts. NMFS excluded an area used by the Navy for training but declined to exclude others requested by Alaska and the North Slope Borough, finding no significant economic impact. The United States District Court for the District of Alaska largely agreed with Alaska, holding that the critical habitat designations were unlawful. The court vacated the rules and remanded the matter to NMFS, concluding that NMFS had not adequately explained why the entire designated area was necessary for the seals’ conservation, had failed to consider foreign conservation efforts and foreign habitat, and had abused its discretion by not considering certain exclusions. The Center for Biological Diversity intervened as a defendant and appealed the district court’s decision. The district court did, however, reject Alaska’s argument that NMFS had failed to comply with the ESA’s “prudency” requirement. On appeal, the United States Court of Appeals for the Ninth Circuit found that it had jurisdiction, reversed the district court’s rulings that the designations were unlawful, and affirmed the court’s ruling on the ESA’s prudency requirement. The Ninth Circuit held that NMFS’s designations complied with the ESA, that the agency was not required to consider foreign conservation efforts or habitat, and that the decision not to exclude certain coastal areas was within its discretion. The critical habitat designations were reinstated, and the case was remanded with instructions to enter judgment for the Center and NMFS. View "STATE OF ALASKA V. NATIONAL MARINE FISHERIES SERVICE" on Justia Law

USA V. FERRARI

2026-03-23T08:31:49-08:00

In this case, law enforcement learned from a confidential informant that Christian Ferrari was manufacturing and selling privately made firearms, commonly called “ghost guns,” without the required federal license or serial numbers, making the weapons untraceable. Between March and May 2023, Ferrari sold 22 unregistered AR-15 style rifles, including 20 short-barreled rifles, to undercover ATF agents in four separate cash transactions. During these sales, Ferrari failed to ask for or provide paperwork, complete background checks, or exchange identification. The agents told Ferrari that the guns were intended for use in protecting marijuana grows in Northern California and for transport to Mexico. Ferrari was charged in the United States District Court for the Southern District of California and pled guilty to four counts of willfully dealing firearms without a license. The Presentence Investigation Report recommended a sentencing enhancement for firearms trafficking under U.S.S.G. § 2K2.1(b)(5), based on Ferrari having “reason to believe” the guns would be used unlawfully. Ferrari objected, arguing there was no evidence he believed the agents were unlawful possessors or would use the guns unlawfully. The district court overruled his objection, finding the totality of circumstances gave Ferrari reason to believe in unlawful use, and applied the enhancement, resulting in a 37-month sentence. On appeal to the United States Court of Appeals for the Ninth Circuit, Ferrari changed his argument, claiming the Sentencing Guidelines required that the transferee in fact be an unlawful possessor or intend unlawful use. The Ninth Circuit, reviewing de novo, held that Application Note 13 to § 2K2.1(b)(5) does not require that what the defendant had reason to believe was actually true. Because Ferrari did not dispute he had reason to believe the agents were unlawful possessors, the district court correctly applied the enhancement. The Ninth Circuit affirmed the sentence. View "USA V. FERRARI" on Justia Law

NAVARRETE V. BONDI

2026-03-23T08:01:54-08:00

A Mexican national attempted to enter the United States in 2003 using fraudulent documents and was removed under an expedited order. After re-entering the country illegally, he was discovered in 2024 and his prior removal order was reinstated. During the reinstatement proceedings, he expressed fear of returning to Mexico and received a reasonable-fear interview, but the asylum officer determined he did not have a reasonable fear of persecution or torture. The immigration judge reviewed and affirmed this negative reasonable-fear determination, meaning he was not eligible for further proceedings to seek withholding of removal or protection under the Convention Against Torture (CAT). After the immigration judge’s decision, the individual filed a petition for review with the United States Court of Appeals for the Ninth Circuit. He did not challenge the original expedited removal order or the reinstated removal order, but instead sought review solely of the denial of CAT relief. The government did not argue that the petition was untimely, but the court requested additional briefing after the Supreme Court’s decision in Riley v. Bondi, which addressed jurisdiction over such petitions. The United States Court of Appeals for the Ninth Circuit held that it lacked jurisdiction to review a petition challenging only an order denying CAT relief when the petitioner did not also seek review of a final order of removal. The court concluded that, under current statutes and Supreme Court precedent, only final orders of removal are reviewable, and an order denying CAT relief does not qualify as a final order of removal nor does it merge into such an order. The court dismissed the petition for lack of jurisdiction and denied the petitioner’s request to amend his petition to add a nominal challenge to the removal order, as any such challenge would be baseless and futile. View "NAVARRETE V. BONDI" on Justia Law

SANDLER V. MODERNIZING MEDICINE, INC.

2026-03-19T08:01:21-08:00

An individual brought suit against her employer, a Delaware corporation, alleging various claims of discrimination based on age and disability under state and federal law. The employment contract between the parties included an arbitration provision, specifying that all employment-related disputes were to be resolved through binding arbitration under the Federal Arbitration Act (FAA), in accordance with procedures outlined in the California Arbitration Act. The contract also incorporated JAMS rules, which assign the arbitrator authority to resolve issues regarding the validity and enforceability of the arbitration agreement itself. The United States District Court for the Southern District of California reviewed the employer’s motion to compel arbitration. The court recognized that the arbitration agreement, by incorporating the JAMS rules, delegated questions about the agreement's validity to an arbitrator. However, relying on California state court decisions, the district court determined that the presence of a severability clause—allowing a court or other competent body to sever invalid provisions—negated a “clear and unmistakable” delegation to the arbitrator. Consequently, the district court concluded it was responsible for determining validity and found the arbitration agreement unconscionable, denying the motion to compel arbitration. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s judgment de novo. The appellate court held that the contract’s delegation clause, by clearly incorporating JAMS rules, unmistakably reserved the issue of the arbitration agreement’s validity for the arbitrator. The existence of a severability clause did not undermine this delegation. The Ninth Circuit reversed the district court’s denial of the motion to compel arbitration, vacated its unconscionability judgment, and remanded with instructions to compel arbitration and stay the case pending arbitration. View "SANDLER V. MODERNIZING MEDICINE, INC." on Justia Law

USA V. MARTINEZ

2026-03-18T08:31:50-08:00

Three individuals were convicted under a federal law that prohibits those with prior misdemeanor convictions for domestic violence from possessing firearms or ammunition. Each had a history of violent conduct against intimate partners, and after their misdemeanor convictions under state law, they were later found in possession of firearms, leading to federal charges under 18 U.S.C. § 922(g)(9). Prior to this appeal, each defendant was convicted in a United States District Court—one in the Northern District of California and two in the District of Alaska—of violating § 922(g)(9). The convictions were based on evidence that after their state-level domestic violence misdemeanor convictions, they knowingly possessed firearms. Following their convictions, the defendants appealed, arguing that § 922(g)(9) is unconstitutional under the Second Amendment, both on its face and as applied to them. The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court applied the framework established by New York State Rifle & Pistol Association, Inc. v. Bruen and United States v. Rahimi, and concluded that the plain text of the Second Amendment covers the appellants’ conduct but that the government demonstrated § 922(g)(9) is consistent with the nation’s historical tradition of firearm regulation. The court rejected both the facial and as-applied constitutional challenges, holding that Congress may categorically disarm those convicted of misdemeanor domestic violence without individualized findings of future dangerousness. The court further held that § 922(g)(9) is constitutional as applied to these appellants and affirmed the judgments of conviction. View "USA V. MARTINEZ" on Justia Law

POWLEY V. BISIGNANO

2026-03-18T08:31:49-08:00

A claimant applied for disability insurance benefits and supplemental security income, alleging a range of physical and mental health impairments. After an initial denial and an earlier remand from the district court, the claimant appeared before a new administrative law judge (ALJ). At the hearing, a vocational expert (VE) testified about the number of jobs in the national economy that someone with the claimant’s limitations could perform. The VE identified three specific jobs and provided job-number estimates, relying on sources such as SkillTRAN and manufacturer databases. The claimant then submitted post-hearing objections and contrary job-number evidence, using similar data sources, including SkillTRAN and the U.S. Census Bureau, to show far fewer available jobs or, in some cases, none at all. The ALJ briefly acknowledged the claimant’s contrary evidence but found it unpersuasive, stating that the VE’s testimony was more reliable due to his professional experience. The Appeals Council denied review, and the claimant then challenged the decision in the United States District Court for the District of Oregon. The district court affirmed, reasoning that the claimant’s alternative job numbers lacked probative value because the evidence did not sufficiently explain the methodology or expertise involved in generating those numbers. On appeal, the United States Court of Appeals for the Ninth Circuit found that the claimant’s counter evidence was both significant and probative, as it was generated using data sources and methods frequently relied upon by the Social Security Administration and showed large discrepancies with the VE’s estimates. The Ninth Circuit held that the ALJ erred by failing to adequately address and resolve the inconsistencies between the competing job-number evidence. The court reversed the district court’s decision and remanded the matter to the agency for further proceedings to resolve these discrepancies. View "POWLEY V. BISIGNANO" on Justia Law

ADVENTIST HEALTH SYSTEM OF WEST V. ABBVIE INC.

2026-03-17T08:01:17-08:00

A healthcare provider operating as a covered entity under the federal Section 340B Drug Pricing Program purchased pharmaceuticals from several drug manufacturers. The provider alleged that these manufacturers engaged in a fraudulent scheme by knowingly charging prices for drugs that exceeded the statutory ceiling, resulting in inflated reimbursement claims submitted to Medicaid, Medicare, and other government-funded programs. The provider did not seek compensation for its own overcharges, but instead brought a qui tam action under the False Claims Act (FCA), seeking to recover losses on behalf of the federal and state governments. The United States District Court for the Central District of California dismissed the complaint with prejudice. It reasoned that, under the Supreme Court’s holding in Astra USA, Inc. v. Santa Clara County, Section 340B does not confer a private right of action for covered entities to sue drug manufacturers over pricing disputes; such claims must instead be pursued through the Section 340B Administrative Dispute Resolution process. The district court concluded that the provider’s FCA claims were essentially attempts to enforce Section 340B and should therefore be barred. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The appellate court held that the provider’s FCA claims were not barred by the absence of a private right of action under Section 340B or by the Astra decision, because the action was brought to remediate fraud against the government and not to recover personal losses or enforce Section 340B directly. The court further found that the provider had plausibly pleaded falsity under the FCA. The Ninth Circuit remanded the case for further proceedings. View "ADVENTIST HEALTH SYSTEM OF WEST V. ABBVIE INC." on Justia Law

USA V. TORRES-GONZALEZ

2026-03-16T08:31:48-08:00

Cruz Torres-Gonzalez was convicted in 2014 for illegal reentry into the United States and for making false statements to federal officers. He received concurrent 35-month sentences for these offenses. In 2024, he was again convicted of illegal reentry. During sentencing for the 2024 conviction, the district court considered his prior convictions and applied sentencing enhancements under the United States Sentencing Guidelines, including an eight-level enhancement based on the 35-month sentence for his prior false-statement conviction. After his 2024 conviction in the United States District Court for the Southern District of California, Torres-Gonzalez objected to the eight-level enhancement. He argued that the sentence for his false-statement offense was not truly independent, as it had been grouped with his illegal reentry conviction in 2014, which carried the highest offense level. He asserted that this grouping made it impossible to determine the appropriate enhancement, and asked the court to apply a lesser, four-level enhancement instead. The district court acknowledged that the grouped sentence likely affected the length of the false-statement sentence but concluded that the guidelines, as written, required the eight-level enhancement. The court imposed a sentence of 51 months. On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo. The appellate court held that the district court correctly applied the guidelines. It found no ambiguity in the relevant guideline provisions and determined that the length of the prior sentence, even if grouped, was the proper basis for the enhancement. The Ninth Circuit affirmed the sentence imposed by the district court. View "USA V. TORRES-GONZALEZ" on Justia Law

COX V. GRITMAN MEDICAL CENTER

2026-03-16T08:01:44-08:00

Susan Cox, a resident of Albion, Washington, died from an alleged overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Susan’s husband, Mark Cox, and her estate initiated a wrongful-death and survivor action against Dr. Marciano and Gritman Medical Center after Susan’s death. The Coxes had lived in Washington, while Dr. Marciano and Gritman are based in Idaho, with all medical treatment having taken place in Idaho. However, at Susan’s request, her prescriptions were regularly transmitted by Dr. Marciano and Gritman to pharmacies in Washington, and Gritman engaged in marketing and accepted patients from the Washington area. The United States District Court for the Eastern District of Washington dismissed the action for lack of personal jurisdiction over the Idaho-based defendants, holding that Washington’s long-arm statute did not reach them and the exercise of jurisdiction would violate due process. The district court also denied the plaintiffs’ request for jurisdictional discovery relating to general personal jurisdiction over Gritman, and did not address the issue of venue. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The Ninth Circuit held that the district court’s exercise of personal jurisdiction over Dr. Marciano and Gritman Medical Center was proper under both Washington’s long-arm statute and the Due Process Clause. The court found that the defendants had sufficient minimum contacts with Washington, as they cultivated relationships with Washington residents and regularly transmitted prescriptions to Washington pharmacies in compliance with Washington law. The court also held that venue was proper in the Eastern District of Washington because a substantial part of the events underlying the claims occurred there. The Ninth Circuit remanded the case for further proceedings and affirmed the dismissal only as to one defendant who was conceded to be properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

ARIZONA MINING REFORM COALITION V. UNITED STATES FOREST SERVICE

2026-03-13T16:01:23-08:00

A federal land exchange was mandated by the Southeast Arizona Land Exchange and Conservation Act, requiring the United States Forest Service to transfer approximately 2,500 acres of National Forest land, including Oak Flat—a site of religious significance to the Apache—to Resolution Copper Mining, LLC, in exchange for over 5,000 acres of private land. The legislation included requirements for tribal consultation, land appraisal, and the preparation of an environmental impact statement (EIS). Following the issuance of a revised Final EIS in 2025, several environmental and tribal groups, as well as individual Apache plaintiffs, challenged the exchange. Their claims spanned the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), the Religious Freedom Restoration Act (RFRA), and the Free Exercise Clause, alleging procedural and substantive deficiencies. Previously, the United States District Court for the District of Arizona denied the plaintiffs’ motions for a preliminary injunction, finding that they had not demonstrated a likelihood of success on any claims relating to the appraisal process, NEPA, consultation, or the National Forest Management Act. A separate group of Apache plaintiffs brought similar claims, including religious liberty challenges, which were also denied—particularly in light of circuit precedent established in Apache Stronghold v. United States. All plaintiff groups appealed and sought further injunctive relief pending appeal. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial for abuse of discretion and affirmed. The court held that plaintiffs had standing and their claims were justiciable, but that none of their arguments were likely to succeed on the merits or raised serious questions. The court specifically found the appraisals and environmental review sufficient, the agency’s tribal consultation adequate, and the religious liberty claims foreclosed by circuit precedent. The denial of a preliminary injunction was affirmed, and all related motions for injunctive relief were denied as moot. View "ARIZONA MINING REFORM COALITION V. UNITED STATES FOREST SERVICE" on Justia Law

IMPERIAL SOVEREIGN COURT OF THE STATE OF MONTANA V. KNUDSEN

2026-03-13T08:31:22-08:00

A group composed of individuals, nonprofits, and businesses in Montana challenged the enforcement of a newly enacted state law, H.B. 359, which prohibited “drag story hours” and “sexually oriented performances” in various locations, including state-funded schools, libraries, public property, and certain businesses. The law imposed criminal, civil, and professional penalties, and also created a private right of action against violators. Plaintiffs contended that the statute violated their rights to freedom of speech under the First Amendment and to due process under the Fifth Amendment, both on its face and as applied to their speech. In the United States District Court for the District of Montana, the plaintiffs moved for a preliminary injunction to prevent state officials from enforcing H.B. 359 while their challenge was pending. The district court found that the plaintiffs had standing, as at least one plaintiff demonstrated a credible threat of enforcement and self-censorship for each challenged provision. The district court then applied the Winter v. Natural Resources Defense Council standard for preliminary injunctions and concluded that plaintiffs were likely to succeed on the merits of their First Amendment claims. The court found H.B. 359 to be a content-based and viewpoint-based restriction on expressive activity that failed strict scrutiny, and further determined the statute was unconstitutionally vague. The court granted a preliminary injunction, barring enforcement of H.B. 359 by the state defendants. The United States Court of Appeals for the Ninth Circuit reviewed the appeal by the Montana Attorney General and Superintendent of Public Instruction. The Ninth Circuit affirmed the district court’s order, holding that the plaintiffs had standing and that the district court did not abuse its discretion. The appellate court held that both the drag-story-hour and sexually-oriented-performance provisions are content-based restrictions on protected expressive activity and are not narrowly tailored to a compelling governmental interest. Accordingly, the preliminary injunction against enforcement of H.B. 359 was affirmed. View "IMPERIAL SOVEREIGN COURT OF THE STATE OF MONTANA V. KNUDSEN" on Justia Law

NETCHOICE, LLC V. BONTA

2026-03-12T08:31:12-08:00

A national trade association representing large online businesses challenged a recently enacted California statute designed to protect minors’ privacy and well-being online. The law imposes specific requirements on businesses whose online services are likely to be accessed by children under eighteen, including obligations regarding data use, age estimation, and restrictions on certain user interface designs known as “dark patterns.” Before the law took effect, the association brought suit in the United States District Court for the Northern District of California, arguing that several provisions were unconstitutional on First Amendment and vagueness grounds, and sought a preliminary injunction to prevent enforcement. The district court initially enjoined the entire statute, finding the association was likely to succeed on its facial First Amendment challenge. On the State’s appeal, the United States Court of Appeals for the Ninth Circuit vacated most of the injunction, affirming only as to a specific requirement regarding Data Protection Impact Assessments and related inseverable provisions, and remanded for the district court to analyze the association’s other facial challenges and the issue of severability under the Supreme Court’s clarified standards in Moody v. NetChoice, LLC. On remand, the district court again enjoined the entire statute and, in the alternative, seven specific provisions. On further appeal, the United States Court of Appeals for the Ninth Circuit held that the association did not meet its burden for a facial challenge to the law’s coverage definition or its age estimation requirement, vacating the injunction as to those. However, the court affirmed the preliminary injunction as to the law’s data use and dark patterns restrictions on vagueness grounds, finding the provisions failed to clearly delineate prohibited conduct. The court vacated the injunction as to the statute’s remainder and remanded for further proceedings on severability. View "NETCHOICE, LLC V. BONTA" on Justia Law

COMBS V. BROOMFIELD

2026-03-12T08:01:10-08:00

The case concerns a habeas corpus petition filed by an individual convicted and sentenced to death for the willful, deliberate, and premeditated murder of Janine Lee in California in 1993. The petitioner had worked with the victim and, after planning the crime, killed her for financial gain and subsequently attempted to cash her checks. Forensic evidence and the petitioner’s confession corroborated his involvement, including details about the killing, use of martial arts training, and subsequent events. Expert testimony at trial highlighted the petitioner’s mental health issues, drug use, and troubled social history, but the jury found him guilty and sentenced him to death. Following his conviction and sentencing, the California Supreme Court affirmed the judgment on direct appeal and summarily denied habeas relief. The United States District Court for the Central District of California denied the federal habeas petition under 28 U.S.C. § 2254, but granted a certificate of appealability for claims of ineffective assistance of counsel during the penalty phase. The petitioner sought to expand the certificate to include additional claims related to competency and juror bias. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of habeas relief. Applying AEDPA deference, the Ninth Circuit held that the California Supreme Court could have reasonably determined that the petitioner failed to make a prima facie case for relief on all penalty-phase ineffective assistance subclaims, including alleged failures to investigate, prepare witnesses, and rebut aggravating evidence. The court also rejected cumulative error and competency claims, and denied a certificate of appealability for juror bias. The panel granted a certificate for one penalty-phase competency subclaim but affirmed its denial. The district court’s denial of habeas corpus relief was affirmed. View "COMBS V. BROOMFIELD" on Justia Law

PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT

2026-03-11T08:01:41-08:00

Two blind individuals, after enrolling at a community college in Los Angeles, were approved for disability accommodations, including accessible course materials and technology. Despite these approvals, they faced repeated barriers in accessing required textbooks, online platforms, library resources, and other educational tools. They also experienced difficulties in receiving their approved accommodations, such as accessible test-taking and note-taking support. These obstacles led to their inability to participate fully in their courses and, in one case, being steered away from certain classes due to their disability. After a jury trial in the United States District Court for the Central District of California, the jury found the college district liable on multiple counts and awarded damages for intentional violations of Title II of the Americans with Disabilities Act (ADA). The district court, however, reduced the damages to only out-of-pocket expenses, concluding that the jury’s award could only be for emotional distress or lost educational opportunities—both of which it believed were not recoverable. The district court also issued injunctive relief. The plaintiffs appealed the reduction of damages. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that, under Supreme Court precedent, emotional distress damages are not available under Title II of the ADA because the statute’s remedies are coextensive with those of the Rehabilitation Act and Title VI of the Civil Rights Act, which do not permit such damages. However, the Ninth Circuit concluded that plaintiffs may recover compensatory damages for loss of educational opportunities resulting from ADA violations. The court found that the jury’s award was supported by evidence and the instructions given. The Ninth Circuit reversed the district court’s remittitur, vacated its judgment as to damages, and remanded with instructions to reinstate the original jury awards. View "PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT" on Justia Law

USA V. TEKOLA

2026-03-09T08:31:20-08:00

Federal agents investigated a fatal fentanyl overdose in Goleta, California, and traced the source to Isaac Tekola. They discovered that Tekola had been selling drugs for years, primarily from his apartment. A search of his apartment revealed significant quantities of fentanyl, cocaine, methamphetamine, and Alprazolam, along with nearly $13,000 in cash, drug paraphernalia, and evidence that drug sales occurred at his residence. Tekola admitted that the cash came from drug dealing, and that a safe in his closet was used to store drugs and proceeds. His cell phone contained numerous messages confirming that his apartment was the hub of his trafficking operation. A grand jury indicted Tekola on several counts of possession with intent to distribute controlled substances under 21 U.S.C. § 841. He pled guilty to all charges without a plea agreement. At sentencing, the United States District Court for the Central District of California applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a premises for the purpose of manufacturing or distributing controlled substances. Tekola argued that, because his apartment was his primary residence, drug trafficking was not a primary or principal use of the premises. The district court found overwhelming evidence that the apartment was used as the central location for his drug business and imposed an above-Guidelines sentence of 105 months. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s application of the Sentencing Guidelines for abuse of discretion. The court held that the district court did not abuse its discretion in applying the § 2D1.1(b)(12) enhancement. The Ninth Circuit clarified that maintaining a primary residence as a central hub for substantial drug trafficking activity qualifies for the enhancement, even if the premises also serve as a residence, affirming Tekola’s sentence. View "USA V. TEKOLA" on Justia Law

CHAIREZ V. MAYORKAS

2026-03-05T11:06:33-08:00

A noncitizen applied to the United States Citizenship and Immigration Services (USCIS) for a U visa, which is available to victims of certain crimes who assist law enforcement. However, he acknowledged being inadmissible to the United States due to prior unlawful entries and removals, and sought a waiver of inadmissibility, which is granted at the discretion of the Secretary of Homeland Security if considered to be in the public or national interest. USCIS denied both his waiver request and his U visa application. He appealed the denials within the agency, but the Administrative Appeals Office dismissed the appeal. After the agency reopened and reconsidered his applications, it again denied both. The plaintiff then filed a suit in the United States District Court for the District of Idaho under the Administrative Procedure Act (APA), challenging the denial of his waiver and U visa. He later amended his complaint to add a claim that USCIS violated his Fifth Amendment right to due process by exhibiting bias. The defendants moved to dismiss for lack of subject matter jurisdiction. The district court granted the motion, holding that the Immigration and Nationality Act (INA) precludes judicial review in district courts of discretionary waiver decisions under 8 U.S.C. § 1182(d)(14). On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s jurisdictional determination de novo. The Ninth Circuit affirmed the dismissal, holding that the agency’s denial of a waiver is within the discretionary authority specified in the INA and thus falls under 8 U.S.C. § 1252(a)(2)(B)(ii), which strips district court jurisdiction. The court clarified that the savings clause in § 1252(a)(2)(D) applies only to petitions for review of final orders of removal in courts of appeals, not to APA suits in district court. The court also found no colorable constitutional claim challenging agency procedures and thus lacked jurisdiction over that claim as well. View "CHAIREZ V. MAYORKAS" on Justia Law

PACITO V. TRUMP

2026-03-05T11:06:32-08:00

The President issued an executive order in January 2025 suspending the entry of all refugees into the United States under the United States Refugee Admissions Program (USRAP), citing concerns about national capacity and security. The Department of State, in response, suspended and later terminated funding for both overseas and domestic refugee resettlement services, including cooperative agreements with resettlement organizations. Plaintiffs, consisting of affected refugees and resettlement agencies, challenged these actions, arguing that the suspension exceeded the President’s statutory authority and that the funding terminations violated the Administrative Procedure Act (APA) and the Refugee Act. Upon review, the United States District Court for the Western District of Washington granted two preliminary injunctions. The first prohibited enforcement of the executive order suspending refugee admissions and related funding, and the second required the reinstatement of terminated cooperative agreements with resettlement agencies. The Government immediately appealed and sought stays of these injunctions. The district court also certified three plaintiff classes and further clarified the scope of its injunctions. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the President acted within his statutory authority under 8 U.S.C. § 1182(f) in suspending refugee admissions and in pausing decisions on refugee applications, and it reversed the district court’s injunctions to the extent they blocked these actions. The court also concluded that suspending overseas refugee processing and related funding did not violate the Refugee Act or the APA. However, the court affirmed the injunction as to the termination of domestic resettlement services, holding that the Government was likely acting contrary to law and arbitrarily and capriciously by failing to provide statutorily mandated resettlement services to admitted refugees. The scope of the injunction was upheld as compliant with recent Supreme Court precedent. View "PACITO V. TRUMP" on Justia Law

MAPLEBEAR INC. V. CITY OF SEATTLE

2026-03-04T09:01:20-08:00

Two companies that operate app-based delivery platforms challenged a Seattle ordinance enacted in 2023, which aims to protect gig economy workers from unwarranted account deactivations. The law requires “network companies” to provide workers with written deactivation policies and mandates that these policies be “reasonably related” to the companies’ safe and efficient operations. The ordinance also delineates examples of impermissible deactivation grounds, such as those based solely on customer ratings or certain background checks. The companies did not contest the general bar on unwarranted deactivations but argued that the notice and deactivation policy requirements violate the First Amendment and that the ordinance is unconstitutionally vague. In the United States District Court for the Western District of Washington, the companies sought a preliminary injunction to prevent the ordinance from taking effect. The district court denied their motion. It found that the ordinance regulates conduct (the act of deactivating accounts) rather than speech, and that any impact on expression is incidental. The court also concluded that the use of “reasonable” in the ordinance was not unconstitutionally vague, pointing to statutory context and specific examples for guidance. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of injunctive relief. The court held that the ordinance regulates nonexpressive conduct, not speech, and thus does not trigger First Amendment scrutiny. Alternatively, if the ordinance were seen as regulating speech, that speech would be commercial in nature, and the law would satisfy the lower level of scrutiny applicable to compelled factual commercial disclosures. The court further held that the ordinance is not unconstitutionally vague, as it provides adequate notice of what is prohibited. The disposition by the Ninth Circuit was to affirm the district court’s denial of injunctive relief. View "MAPLEBEAR INC. V. CITY OF SEATTLE" on Justia Law

TALON DIVERSIFIED HOLDINGS INC. V. BECKER

2026-03-03T09:31:16-08:00

Richard and Lucia Parks, along with their family real estate business Parks Diversified, L.P. and related entities, became involved in a legal dispute after their son, David Klein, filed a voluntary Chapter 11 bankruptcy petition on behalf of Parks Diversified. The Parkses asserted that Klein did not have the authority to file the petition and claimed he did so as part of a scheme to take control of family assets. Despite these objections, the parties entered into a stipulation to dismiss the bankruptcy case, with the Parkses waiving certain claims. Later, the Parkses and their entities filed a complaint in California state court against Klein and others, alleging various causes of action related to the alleged unauthorized bankruptcy filing. Following this, the law firm representing some of the defendants requested the bankruptcy court to reopen the case, and the state court complaint was removed to the bankruptcy court. The bankruptcy court dismissed the claims for failure to state a claim and granted special motions to strike. On appeal, the United States District Court for the Central District of California found that the bankruptcy court had subject-matter jurisdiction over the case, holding that the issue of corporate authority to file a bankruptcy petition was not jurisdictional. The district court remanded with instructions to vacate orders where jurisdiction was lacking and to remand remaining claims to state court. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that, consistent with precedents from the Second and Third Circuits, a lack of corporate authority to file a bankruptcy petition does not deprive the bankruptcy court of subject-matter jurisdiction. The court clarified that while proper authorization is mandatory, it is not jurisdictional, and thus affirmed the lower court’s conclusion on this point. View "TALON DIVERSIFIED HOLDINGS INC. V. BECKER" on Justia Law

USA V. BOYLAN

2026-03-03T09:01:07-08:00

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation. The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty. On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law

CENTER FOR BIOLOGICAL DIVERSITY V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

2026-03-03T09:01:07-08:00

The case concerns a challenge brought by an environmental non-profit against the U.S. Environmental Protection Agency (EPA) relating to the agency’s 2016 national recommendations for allowable cadmium levels in water. The EPA, as required by the Clean Water Act (CWA), periodically issues nonbinding criteria for water pollutants, which states typically adopt as standards for their own waters. In 2016, the EPA updated its cadmium recommendations but did so without consulting the Fish and Wildlife Service or the National Marine Fisheries Service, as mandated under Section 7 of the Endangered Species Act (ESA) for actions that may affect protected species. Previously, the United States District Court for the District of Arizona found that the Center for Biological Diversity (CBD) had standing to challenge the EPA’s failure to consult. The district court granted summary judgment in favor of CBD, holding that the EPA’s issuance of the cadmium recommendations constituted “agency action” under the ESA that “may affect” listed species, thus triggering the consultation requirement. The court vacated the less stringent chronic freshwater cadmium recommendation and remanded all four 2016 cadmium recommendations to the EPA for proper consultation. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that CBD had Article III standing, finding a concrete injury to its members’ interests in protected species, that the injury was fairly traceable to EPA’s recommendations due to predictable state adoption, and that the injury could be redressed by stricter recommendations resulting from consultation. On the merits, the court concluded that EPA’s publication of nationwide recommendations was “agency action” under the ESA and that such action “may affect” listed species, thus requiring prior consultation with the Services. The district court’s vacatur and remand were affirmed. View "CENTER FOR BIOLOGICAL DIVERSITY V. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY" on Justia Law

City of Culver City v. Federal Aviation Administration

2026-03-02T11:03:47-08:00

The Federal Aviation Administration (FAA) introduced new and revised air traffic procedures in the Southern California Metroplex as part of its Next Generation Air Transportation System (NextGen) initiative in 2016, affecting airports including Los Angeles International Airport. These procedures, specifically the HUULL, IRNMN, and RYDRR routes, relied on satellite navigation and were subject to an environmental review, which concluded there would be no significant noise impacts. In 2018, the FAA amended these procedures, making minor changes to altitude and speed restrictions at certain waypoints, with no changes to flight paths, number of flights, or aircraft types. Only one amended waypoint affected Malibu, and none affected Culver City. Previously, Culver City and other parties challenged the FAA’s 2016 approval in the United States Court of Appeals for the District of Columbia Circuit, which upheld the FAA’s decision. After the 2018 amendments, the City of Los Angeles and Culver City (as intervenor) challenged the FAA’s actions in the United States Court of Appeals for the Ninth Circuit, which found violations of environmental statutes but remanded for further review without vacating the procedures. The FAA then conducted additional environmental consultations and issued a Record of Decision, concluding the amendments qualified for a categorical exclusion from further environmental review. The United States Court of Appeals for the Ninth Circuit reviewed the petitions from Malibu and Culver City regarding the FAA’s 2018 amendments. The court held that only challenges to the 2018 amendments were timely, dismissing any challenge to the original 2016 procedures as untimely. The court determined that neither city demonstrated standing to challenge the 2018 amendments: Malibu’s evidence addressed only the 2016 procedures, and Culver City failed to provide evidence of injury. The petitions were dismissed for lack of standing. View "City of Culver City v. Federal Aviation Administration" on Justia Law

L.B. V. SAN DIEGO UNIFIED SCHOOL DISTRICT

2026-02-27T13:31:27-08:00

A middle school student with significant mental health needs struggled academically and emotionally while enrolled in a public school district during the COVID-19 pandemic, when instruction was provided virtually. His parents, finding that the school’s Individualized Education Program (IEP) was inadequate to address his needs during this period, placed him in two successive out-of-state private residential treatment centers offering in-person education and mental health services. Throughout this time, the parents participated in several meetings with the district’s IEP Team and communicated their concerns about the insufficiency of the educational program provided. Afterward, the parents sought reimbursement from the school district for the costs associated with the residential placements, arguing that the district failed to offer their child a free appropriate public education (FAPE) as required under the Individuals with Disabilities Education Act (IDEA). An Administrative Law Judge (ALJ) denied their claim, concluding that the district had no duty to offer a FAPE during the relevant period because the parents had not expressly requested a new IEP document, and instead, had only requested IEP meetings. The United States District Court for the Southern District of California affirmed this determination, also reasoning that the parents’ requests for meetings did not obligate the district to develop or offer a new IEP. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that under both federal and California law, the purpose of an IEP meeting is to develop or revise an IEP that offers a FAPE. The court concluded that it was irrelevant whether the parents had requested an IEP “meeting” or an IEP “document,” and that participation in IEP meetings triggered the district’s ongoing obligation to offer a FAPE. The Ninth Circuit reversed the district court’s decision and remanded for further proceedings to determine whether the IEP offered satisfied the IDEA’s requirements and, if not, whether the student was entitled to reimbursement or other remedies. View "L.B. V. SAN DIEGO UNIFIED SCHOOL DISTRICT" on Justia Law

Wells v. BNSF Railway Co.

2026-02-24T09:31:18-08:00

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period. This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

LA International Corp. v. Prestige Brands Holdings, Inc.

2026-02-24T09:31:15-08:00

A group of wholesale businesses that purchased Clear Eyes Redness Relief eye drops from a manufacturer alleged that the manufacturer sold the product at unlawfully lower prices to their larger competitors, specifically Costco and Sam’s Club. The manufacturer provided these large buyers with discounts and customer rebates not offered to the wholesalers, resulting in a significant price advantage for Costco and Sam’s Club. The wholesalers claimed that this conduct made it impossible for them to compete effectively and sought relief under the Robinson-Patman Act, as well as California’s Unfair Practices Act and Unfair Competition Law. The case was tried in the United States District Court for the Central District of California. The jury found in favor of the wholesalers on their federal claims and awarded damages, except for one wholesaler that was not found to be in direct competition with Costco. The district court also found in favor of the California-based wholesalers on the state claims, entered judgment for the wholesalers, awarded damages, and issued a permanent injunction against the manufacturer. The court also awarded attorney’s fees but reduced the requested amount based on the size of the plaintiffs’ law firm rather than prevailing market rates. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment in favor of the wholesalers on all substantive issues. The appellate court held that the district court properly instructed the jury, correctly included customer rebates in the price discrimination calculation, and appropriately issued a permanent injunction. However, the Ninth Circuit vacated the district court’s award of attorney’s fees, holding that a law firm's size alone cannot determine the market rate for a lodestar calculation. The case was remanded for recalculation of attorney’s fees consistent with prevailing market rates. View "LA International Corp. v. Prestige Brands Holdings, Inc." on Justia Law

USA V. MOTLEY

2026-02-24T09:01:07-08:00

The defendant operated two companies that provided durable medical equipment, both of which were enrolled as Medicare providers under the names of her mother and nephew. The defendant orchestrated a scheme where patient information was used to submit fraudulent claims for unnecessary medical equipment and repairs, with the assistance of other employees and marketers. Over a ten-year period, the companies submitted more than $24 million in claims, of which Medicare paid approximately $13 million. The United States District Court for the Central District of California presided over the case. The defendant was indicted and, after a second trial, convicted by a jury of conspiracy to launder monetary instruments, healthcare fraud, and aggravated identity theft under 18 U.S.C. § 1028A(a)(1), based on the use of her relatives’ names during the commission of health care fraud. The district court sentenced her to a total of 180 months in custody, including a mandatory consecutive two-year term for aggravated identity theft. The defendant appealed her convictions for aggravated identity theft. The United States Court of Appeals for the Ninth Circuit reviewed the case. The main issue on appeal was whether the use of her relatives’ names constituted aggravated identity theft under the standard clarified in Dubin v. United States, 599 U.S. 110 (2023). The Ninth Circuit held that the government failed to show that the use of the relatives’ names was “at the crux” of the fraud—meaning that the use itself was fraudulent or deceitful and critical to the scheme’s success, as required by Dubin. The court vacated the defendant’s sentence for aggravated identity theft and remanded the case to the district court for resentencing. The healthcare fraud and other convictions were not in dispute. View "USA V. MOTLEY" on Justia Law

USA V. ALAVEZ

2026-02-20T09:01:36-08:00

In this case, the defendant, a Mexican citizen residing in the United States, traveled to Hawaii in June 2023, where he rented a studio apartment. A suspicious package addressed to a name similar to his arrived at the property owner’s residence. After the owner opened the package and suspected it contained drugs, she turned it over to law enforcement. The package was later confirmed to contain nearly 5 kilograms of a methamphetamine mixture. The defendant was arrested and interviewed, during which he admitted to being recruited to pick up and deliver a package and to wire money linked to drug trafficking, though he claimed not to know the specific type or quantity of drugs involved. The United States District Court for the District of Hawaii presided over the trial. A jury convicted the defendant on charges of conspiracy to possess and attempted possession with intent to distribute 500 grams or more of methamphetamine. The district court sentenced him to concurrent ten-year prison terms. The defendant appealed, arguing that the jury instructions were improper regarding his knowledge of the drug’s type and quantity, and that religious images and expert testimony admitted at trial were prejudicial. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that, under United States v. Hunt, the government must prove the defendant’s specific intent to possess the particular drug type and quantity to trigger the heightened penalty under 21 U.S.C. § 841(b)(1)(A)(viii). The district court’s jury instruction relieving the government of this burden was not harmless error. Therefore, the Ninth Circuit vacated the sentence for attempted possession but not the conviction itself, remanding for resentencing. The court affirmed the convictions, finding that any error in admitting expert testimony about “narco saints” was harmless. The judgment was thus affirmed in part, vacated in part, and remanded. View "USA V. ALAVEZ" on Justia Law

United States v. Ho-Romero

2026-02-18T09:31:08-08:00

David Ho-Romero was stopped at the border near San Diego in February 2021, and authorities discovered over 11 kilograms of methamphetamine in his vehicle. He was subsequently indicted for importing methamphetamine. During the investigation, prosecutors called Witness 1, Ho-Romero’s former romantic partner, to testify before a grand jury. After learning of Witness 1’s involvement from his roommate, Ho-Romero contacted Witness 1 and her friend (Witness 2), making statements that the government interpreted as threats. Based on these communications, Ho-Romero was charged with witness tampering but pled guilty only to drug importation, not to tampering. The parties agreed to dismiss the tampering charges in exchange for Ho-Romero stipulating to the admissibility of Witness 1 and Witness 2’s grand jury testimony. The United States District Court for the Southern District of California ordered a presentence report recommending an obstruction of justice enhancement under U.S.S.G. § 3C1.1. Defense counsel objected, arguing Ho-Romero did not willfully obstruct justice. At sentencing, the district court applied the enhancement, interpreting “willfulness” as an objective standard without requiring a finding of specific intent to obstruct justice. The court found only that Ho-Romero’s statements could be understood as threats. With the enhancement, the Guidelines range increased, but the court imposed a downward departure, sentencing Ho-Romero to 60 months imprisonment and five years of supervised release. Ho-Romero appealed. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo for legal error. The court held that § 3C1.1 requires a finding that the defendant acted with the specific intent to obstruct justice, citing United States v. Lofton as controlling law. The district court erred by not making such a mens rea finding. The Ninth Circuit vacated the sentence and remanded for resentencing, requiring proper findings as to Ho-Romero’s conscious purpose to obstruct justice. View "United States v. Ho-Romero" on Justia Law

USA V. BRANDENBURG

2026-02-17T09:01:08-08:00

Bryan Brandenburg remotely participated in divorce proceedings at a courthouse in Salt Lake City, Utah. Following the proceedings, Brandenburg sent increasingly hostile emails to court staff, which ultimately escalated to threats of bombing the courthouse and other government and educational institutions, as well as various targets elsewhere. His threats prompted extensive security responses at the courthouse, including enhanced screenings, patrols, surveillance reviews, and coordination with law enforcement. Additionally, threats to journalists led to security measures at the University of Utah and Hall Labs, including evacuations, sweeps, and diversion of law enforcement resources during significant campus events. The United States District Court for the District of Hawaii presided over Brandenburg’s criminal trial. A jury convicted him of transmitting threats in interstate commerce and making threats or false statements about explosives. At sentencing, the government requested a sentencing enhancement under U.S. Sentencing Guideline § 2A6.1(b)(4)(A), arguing that Brandenburg’s actions caused a substantial disruption of governmental functions. The district court agreed, finding that the courthouse security staff’s extensive response constituted such a disruption, and imposed the enhancement. Brandenburg appealed both his conviction and the sentencing enhancement. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a non-public-facing security response to a threat can qualify as a substantial disruption of governmental functions under § 2A6.1(b)(4)(A). The Ninth Circuit determined that the district court properly evaluated the scope and duration of the disruption and did not abuse its discretion in applying the enhancement. The court affirmed the district court’s decision, upholding the sentencing enhancement for substantial disruption of governmental functions. View "USA V. BRANDENBURG" on Justia Law

COX V. GRITMAN MEDICAL CENTER

2026-02-11T09:01:06-08:00

Susan Cox, a resident of Albion, Washington, died from an overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Dr. Marciano, along with Gritman Medical Center, both based in Idaho near the Washington border, had treated Susan for several years. Although Susan lived in Washington, her medical treatment occurred in Idaho. At Susan’s request, her prescriptions were regularly transmitted to pharmacies in Washington. Susan’s husband, Mark Cox, and her estate brought a wrongful death and survivor action in the Eastern District of Washington, alleging that Susan’s death resulted from negligent over-prescription of pharmaceuticals. The United States District Court for the Eastern District of Washington denied the plaintiffs’ request for jurisdictional discovery regarding general personal jurisdiction over Gritman and dismissed the case for lack of personal jurisdiction. The district court found that Washington’s long-arm statute did not confer jurisdiction and that exercising specific jurisdiction would violate due process, as the defendants had not purposefully availed themselves of the Washington forum. The district court did not reach the question of venue. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The court of appeals held that the district court’s exercise of personal jurisdiction over the Idaho defendants was proper under Washington’s long-arm statute and consistent with the Due Process Clause because the defendants maintained ongoing, deliberate relationships with Washington residents and regularly sent prescriptions to Washington pharmacies in compliance with state law. The court also held that venue was proper in the Eastern District of Washington since a substantial part of the events underlying the claims occurred there. The case was remanded for further proceedings, with dismissal affirmed only for one defendant whom the plaintiffs conceded was properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

USA V. ENGSTROM

2026-02-05T09:01:20-08:00

Paul Engstrom pleaded guilty to conspiracy to distribute a controlled substance and money laundering conspiracy, admitting to involvement in distributing 500 grams or more of cocaine—an offense carrying a five-year mandatory minimum sentence. In his plea agreement, Engstrom acknowledged he was ineligible for safety valve relief under 18 U.S.C. § 3553(f) and agreed not to seek such relief. At sentencing in the United States District Court for the District of Nevada, the court imposed a 70-month sentence, below the guideline range but above the statutory minimum, citing Engstrom’s difficult pretrial detention and his coconspirators’ similar sentences. Following sentencing, the district court held a resentencing hearing pursuant to Federal Rule of Criminal Procedure 35, aiming to correct a perceived technical error in considering the mandatory minimum after granting Engstrom safety valve relief. The court concluded that Engstrom was eligible for safety valve relief, finding that his statements in open court were sufficient, and imposed a 46-month sentence, below the statutory minimum. The government moved for reconsideration, arguing Engstrom had not satisfied the statutory debrief requirement and was ineligible under the Supreme Court’s decision in Pulsifer v. United States, issued during the appeal, which interpreted § 3553(f)(1) to preclude safety valve relief if any one of three criminal history criteria applied. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s resentencing decision for plain error and found no error in holding the Rule 35 hearing. However, the Ninth Circuit held that Engstrom was not eligible for safety valve relief because he did not provide a complete debrief to the government as required by § 3553(f)(5), and, under Pulsifer, his prior three-point conviction categorically precluded relief. The court reversed the district court, vacated Engstrom’s sentence, and remanded for resentencing without safety valve relief. View "USA V. ENGSTROM" on Justia Law

Construction Laborers Pension Trust of Greater St. Louis v. Funko, Inc.

2026-02-04T10:07:44-08:00

Funko, Inc., a company specializing in pop culture collectibles, experienced a significant decline in its share price after writing off millions of dollars in unsellable inventory. Shareholders who purchased Funko stock during the relevant period alleged that Funko and its key officers misled investors about the progress of relocating to a new warehouse, the quality and management of inventory, the status of its information technology upgrades, and its distribution capabilities. The plaintiffs claimed that these misrepresentations led them to buy stock at artificially inflated prices. The period in question was marked by Funko's transition to a larger distribution center and a planned upgrade of its enterprise resource planning software, both of which encountered serious operational difficulties that impacted inventory management and order fulfillment. The United States District Court for the Western District of Washington dismissed the complaint, holding that the plaintiffs failed to sufficiently allege falsity and scienter—a necessary intent to mislead investors or recklessness to the risk of doing so. The district court found that most of the challenged statements were either not objectively false, constituted non-actionable puffery, or were protected as forward-looking statements under the Private Securities Litigation Reform Act’s safe harbor. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the dismissal in part and reversed in part. The Ninth Circuit held that while Funko’s affirmative statements about the distribution center operations, inventory quality, and distribution capabilities were not demonstrably false or actionable, certain risk disclosures in Funko’s SEC filings regarding inventory management and its use of existing information technology systems were misleading. The court found that these risk disclosures implied the risks were merely hypothetical when, in fact, they had already materialized. The court also found sufficient allegations of scienter, concluding that senior officers likely knew their statements were misleading. The court reversed the dismissal of claims related to those disclosures and remanded for further proceedings. View "Construction Laborers Pension Trust of Greater St. Louis v. Funko, Inc." on Justia Law

Harris v. Muhammad

2026-02-04T09:32:07-08:00

A California state prisoner, Maurice Lydell Harris, is a practicing Nichiren Buddhist who believes his faith requires him to eat “clean” food, including meat as close to its natural state as possible. Because the prison system did not offer a diet specifically aligned with his religious practice, Harris enrolled in the halal meat program (RMAP), based on advice from a prison chaplain that it most closely matched his requirements. Prison regulations require RMAP participants to refrain from buying non-halal foods from the commissary, but Harris purchased such items, including ramen and processed meats, citing health needs and cultural practices, which led to multiple violations and ultimately his removal from the program. Harris filed suit in the United States District Court for the Northern District of California, alleging that his removal from RMAP violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought preliminary injunctive relief to continue receiving the RMAP diet while supplementing with non-halal foods. The district court denied Harris’s requests twice, concluding that the RMAP diet was not required by Harris’s religion and that expulsion would not affect his ability to observe his faith. On appeal, the United States Court of Appeals for the Ninth Circuit found that the district court erred by evaluating the centrality of the halal diet to Harris’s beliefs, rather than whether Harris sincerely believed the diet best suited his religious needs. The Ninth Circuit held that Harris could demonstrate a substantial burden on his religious exercise and that, if so, the government must show its regulation is the least restrictive means of advancing a compelling interest. The court vacated the district court’s denial of a preliminary injunction and remanded for further proceedings to reassess whether Harris’s religious exercise was substantially burdened. View "Harris v. Muhammad" on Justia Law

Fiedler v. United States

2026-01-30T09:31:32-08:00

A fire broke out on the passenger dive boat M.V. Conception during a scuba diving excursion in September 2019, resulting in the deaths of thirty-four people who were trapped below deck. The Coast Guard had inspected the vessel multiple times before the incident and had found it fit for service, not identifying any safety hazards related to electrical wiring, plastic trash cans, or plastic chairs. Personal representatives of the deceased and one injured survivor filed suit against the United States, alleging that the Coast Guard’s negligent inspection and failure to identify these hazards caused the tragedy. The United States District Court for the Central District of California was the first to review the case. The government moved to dismiss the action for lack of subject matter jurisdiction, arguing that the discretionary function exception to the Suits in Admiralty Act (SIAA) applied. The district court agreed, finding that the relevant statutes and regulations gave Coast Guard inspectors discretion in how to conduct vessel inspections and in determining what constituted hazardous conditions. As a result, plaintiffs’ claims were barred by the discretionary function exception, and the suit was dismissed. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that its prior precedent, Earles v. United States, which applies the discretionary function exception from the Federal Tort Claims Act (FTCA) to the SIAA, remained binding and had not been overruled by the Supreme Court’s decision in Thacker v. Tennessee Valley Authority. The court further found that no specific statute, regulation, or policy required the Coast Guard to identify the hazards alleged by plaintiffs, and that the inspection process involved discretionary, policy-based decisions. Accordingly, the discretionary function exception barred the suit, and dismissal for lack of subject matter jurisdiction was proper. View "Fiedler v. United States" on Justia Law