This case concerns a former inmate's civil rights lawsuit against Los Angeles County Sheriff Leroy Baca, alleging that Baca's failure to address prior incidents of inmate violence violated the Eighth Amendment by allowing correctional officers to facilitate an assault on the plaintiff. The Ninth Circuit panel reversed the district court's dismissal of the claim against Baca in his supervisory capacity, and a majority of active judges declined to rehear the case en banc. The core reasoning, as set out in the published order and dissent, centers on whether the complaint's allegations of unrelated prior violence incidents meet the plausibility pleading standard from Twombly and Iqbal and establish a causal link to the specific incident rather than supporting vicarious liability.
In this case, inmate Dion Starr sued Los Angeles County Sheriff Leroy Baca in his individual capacity under 42 U.S.C. § 1983, alleging that Baca was deliberately indifferent to dangerous conditions in the county jail in violation of the Eighth and Fourteenth Amendments. Starr claimed that jail deputies allowed other inmates to attack him and then further abused him, and that Baca knew or should have known of the risks based on prior incidents but failed to act. The district court dismissed the supervisory liability claim against Baca for failure to state a claim under Rule 12(b)(6). The Ninth Circuit reversed, holding that the complaint's factual allegations of Baca's knowledge and inaction were sufficient to plead a causal connection under the pleading standards of Ashcroft v. Iqbal and circuit precedent on supervisory liability. The court remanded for further proceedings, while a dissent argued that the allegations were too conclusory to establish personal involvement by Baca.
The case involved two Mexican nationals charged with illegal entry into the United States who participated in a group plea hearing under the District of Arizona's Operation Streamline program, where a magistrate judge explained rights and took guilty pleas from dozens of defendants at once. The defendants appealed, arguing that the collective nature of the hearing violated their Fifth Amendment due process rights by failing to ensure their pleas were knowing and voluntary as required by Boykin v. Alabama. The Ninth Circuit Court of Appeals affirmed the convictions, holding that the record sufficiently demonstrated the pleas were voluntary and intelligent because the defendants had access to counsel, were advised of their rights collectively, and had opportunities to ask questions or request trials individually. The court reasoned that Boykin does not mandate individualized waivers but only requires affirmative evidence of a knowing plea on the record, which was present here, and the defendants failed to show any plain error affecting their substantial rights.
The case involved Ameyalli Escamilla-Rojas, a Mexican citizen charged with illegal entry under 8 U.S.C. § 1325, who participated in a group plea hearing under the District of Arizona's Operation Streamline program alongside 66 other defendants. She appealed her conviction after pleading guilty, arguing that the en masse advisements and individual colloquies violated Federal Rule of Criminal Procedure 11 as well as her Fifth Amendment due process rights and Sixth Amendment right to counsel, including claims that she could not silently waive rights by not standing and that she was separated from her attorney. The Ninth Circuit affirmed the plea and sentence, holding that the magistrate judge's collective explanation of rights, charges, and penalties followed by individualized questioning satisfied Rule 11 and constitutional requirements by confirming each defendant's understanding and voluntary waiver. The court further reasoned that any temporary separation from counsel during the group portion had no probable effect on the fairness or outcome of the proceeding, as counsel met with her beforehand, stood with her during the individual plea, and raised no further objections.
The case involved a lawsuit by the Freedom from Religion Foundation challenging the constitutionality of federal and state parsonage tax exemptions for ministers' housing allowances under the Establishment Clause. Pastor Michael Rodgers, who claimed the exemptions, sought to intervene as a defendant, both as of right and permissively, but the district court denied the motion. The Ninth Circuit affirmed the denial of intervention as of right because existing parties adequately represented Rodgers's interests and his stake was not impaired. It vacated and remanded the denial of permissive intervention, ruling that the district court applied the wrong legal standard by requiring independent jurisdictional grounds, which does not apply to intervenors raising no new claims in federal-question cases.
The case involved David Nosal, who was indicted for violations of the Computer Fraud and Abuse Act after former colleagues at Korn/Ferry used their authorized access to the company's confidential database to obtain proprietary information for Nosal's competing business. The district court dismissed several counts, relying on prior precedent to hold that employees do not exceed authorized access when they obtain information they are permitted to view, even if for an improper purpose. The Ninth Circuit reversed, interpreting the CFAA to cover accessing information for a purpose that violates an employer's restrictions on use, provided there is intent to defraud and the conduct furthers a fraud while obtaining something of value. The court reasoned that the statute's specific intent and causation elements limit its application to non-innocuous violations and align with congressional goals regarding computer-related crimes.
