Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Ninth Circuit

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The Ninth Circuit affirmed the district court's judgment for the Mayo Clinic in an action alleging employment discrimination under Title I of the Americans with Disabilities Act. In light of Supreme Court precedent, the panel held that its decision in Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005), holding ADA discrimination claims are evaluated under a motivating factor causation standard, is no longer good law. The panel held that Head was irreconcilable with the Supreme Court's decisions in Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009), and Univ. of Texas Southwestern Med. Ctr. v. Nassar, 570 U.S. 338 (2013). The panel agreed with its sister circuits and held that an ADA discrimination plaintiff bringing a claim under 42 U.S.C. 2112 must show that the adverse employment action would not have occurred but for the disability. Therefore, the district court correctly instructed the jury to apply a but for causation standard, rather than a motivating factor standard. View "Murray v. Mayo Clinic" on Justia Law

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The Ninth Circuit affirmed the district court's grant of summary judgment for Medtronic in an employment discrimination action brought by plaintiff under the Americans with Disabilities Act (ADA). Plaintiff alleged that he was terminated based on his morbid obesity, but the district court held that morbid obesity was not a physical impairment under the relevant EEOC regulations and interpretive guidance. The panel held that it need not determine whether morbid obesity itself is an impairment under the ADA, and affirmed the district court's judgment for Medtronic on alternative grounds. The panel held that, even assuming that morbid obesity were an impairment, or plaintiff suffered from a disabling knee condition that the district court could have considered, he would have to show some causal relationship between these impairments and his termination. In this case, there was no basis for concluding that he was terminated for any reason other than Medtronic's stated ground that he falsified records to show he had completed work assignments. View "Valtierra v. Medtronic Inc." on Justia Law

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Members of the Tribe filed suit under 42 U.S.C. 1983, alleging violations of various federal statutory and constitutional rights, stemming from traffic citations issued to members of the Tribe from a sheriff's deputy inside the boundaries of the Chemehuevi Reservation. The district court subsequently granted summary judgment to defendants. The panel held that the Chemehuevi Reservation includes Section 36, and that Section 36 is Indian country. Therefore, the County does not have jurisdiction to enforce California regulatory laws within it. Furthermore, the panel held that the individual members have a cause of action under section 1983 against defendants. However, the Tribe cannot assert its sovereign rights under the statute. Accordingly, the court affirmed in part, vacated in part, and remanded in part. View "Chemehuevi Indian Tribe v. McMahon" on Justia Law

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The Ninth Circuit affirmed the district court's denial of petitioner's successive habeas corpus petition challenging the Idaho Supreme Court's 2008 decision that his execution was not barred under an Idaho law prohibiting the execution of intellectually disabled offenders. Petitioner sought relief under Atkins v. Virginia, 536 U.S. 304 (2002), which held that the Eighth Amendment prohibits the execution of intellectually disabled persons. The panel held that the record did not establish that the state court's adjudication of petitioner's Atkins claim resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court, or was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. Therefore, the district court properly denied habeas relief because section 2254(d) was not satisfied. Finally, the panel noted that its decision did not preclude the Idaho courts from reconsidering these questions in light of Hall v. Florida, 572 U.S. 701 (2014); Brumfield v. Cain, 135 S. Ct. 2269 (2015); and Moore v. Texas, 137 S. Ct. 1039 (2017), which were all decided after the state court's decision View "Pizzuto v. Blades" on Justia Law

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The Ninth Circuit affirmed the district court's dismissal of an action alleging claims under the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act. The panel held that plaintiffs failed to exhaust their administrative remedies under the Individuals with Disabilities Education Act (IDEA), because their section 504 and ADA claims concerned whether the child was provided appropriate education services. In this case, plaintiffs settled their IDEA case without receiving an administrative decision on whether plaintiffs' son needed the placement they now assert was required for him to receive a free and appropriate public education. View "Paul G. v. Monterey Peninsula Unified School District" on Justia Law

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The Association filed suit challenging Montana's electioneering disclosure laws on First Amendment grounds. Under Montana law, an organization that makes an expenditure of more than $250 on a single electioneering communication must register as a political committee, subject to certain organizational and disclosure requirements. The Ninth Circuit affirmed the district court's grant of summary judgment for Montana except with respect to one provision. Like the disclosure provisions the panel approved in Human Life of Washington Inc. v. Brumsickle, 624 F.3d 990, 1016 (9th Cir. 2010), and Yamada v. Snipes, 786 F.3d 1182 (9th Cir. 2015), the panel held that most of Montana's disclosure and related requirements are substantially related to important governmental interests connected with informing the electorate. However, the panel held that only Montana's requirement that organizations designate a treasurer registered to vote in Montana is constitutionally infirm. In this case, the requirement was not substantially related to any important governmental interest, and was severable from the rest of the disclosure regime. View "National Association for Gun Rights, Inc. v. Mangan" on Justia Law

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The Ninth Circuit denied an application for authorization to file a second or successive 28 U.S.C. 2254 habeas corpus petition. The panel held that the Supreme Court has not made Riley v. California, 573 U.S. 373 (2014), which held that a warrant is generally required to search a cell phone's data, retroactive. Therefore, the applicant has not made a prima facie showing that his application to file a section 2254 petition met the requirements of 18 U.S.C. 2244(b)(2)(A). View "Young v. Pfeiffer" on Justia Law

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The Ninth Circuit affirmed the district court's denial of the petition for habeas corpus relief challenging petitioner's capital sentence. Petitioner's conviction for first degree murder and related burglary and kidnapping counts stemmed from his armed robbery of a jewelry store. The panel agreed with, and followed, the district court's application of Cullen v. Pinholster, 563 U.S. 170 (2011), and based its decision only on the record before the California Supreme Court (including the trial court record) and did not consider the evidence presented in the federal court evidentiary hearing. The panel held that there were reasonable grounds to support the denial of relief by the state court on petitioner's claims of ineffective assistance of counsel. In this case, the California Supreme Court did not unreasonably apply federal law by determining that counsel's performance was not constitutionally deficient for failing to investigate mitigation evidence regarding petitioner's mother and petitioner's mental impairments. Furthermore, petitioner was not prejudice by counsel's performance. View "Livaditis v. Davis" on Justia Law

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The Ninth Circuit affirmed the district court's denial of Nevada's Federal Rule of Civil Procedure 60(b)(6) motion for relief from the district court's judgment granting on remand petitioner's habeas corpus petition challenging his first degree murder conviction. At issue was whether the Nevada Supreme Court has, since the panel's prior decision in this case, changed the elements for first-degree murder in Nevada in 1991, when petitioner's murder conviction became final. The panel held that intervening Nevada Supreme Court cases did not change the law or undermine Riley I. Therefore, because there was no change in the law that affected Riley I's interpretation of the required elements for first-degree murder in Nevada, the district court did not abuse its discretion by denying the state's motion. View "Riley v. Filson" on Justia Law

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The Ninth Circuit reversed the district court's denial of habeas relief on a certified claim of ineffective assistance of counsel at the penalty phase. Petitioner was convicted and sentenced to death by a California jury on two counts of first-degree murder for killings he committed during a carjacking. The panel held that the California Supreme Court unreasonably applied clearly established federal law in denying petitioner's claim for ineffective assistance of counsel at the penalty phase. Reviewing de novo counsel's performance under Strickland v. Washington, the panel held that counsel rendered deficient performance by failing adequately to investigate petitioner's good character and social history, and he had no reasoned or tactical excuse for not doing so. The panel also held that counsel rendered deficient performance by not investigating petitioner's claim of self-defense in the jail homicide to counter the State's use of it as aggravation evidence. Furthermore, the state court's conclusion that petitioner failed to show prejudice was objectively unreasonable. Accordingly, the panel remanded with instructions. View "Avena v. Chappell" on Justia Law