The case concerned a dispute between AmerisourceBergen Corporation and its former executive Donald Roden over an employment agreement, including entitlement to benefits under an ERISA-governed retirement plan and repayment terms for a company loan, with related claims already pending in California state court. After the state court issued orders on benefits and loan timing, the company filed a federal diversity action seeking damages for breach of contract on the loan and declaratory relief on the proper calculation of retirement benefits. The district court dismissed the federal suit under the Younger abstention doctrine to avoid interfering with the ongoing state proceedings. The Ninth Circuit reversed, holding that abstention was not required because the federal claims were not duplicative of the state action, did not seek to enjoin state proceedings, and could proceed without undermining principles of comity or judicial economy.
The case concerned whether a California minute order, combined with a charging document, could establish that Michael Snellenberger's 1991 nolo contendere plea to burglary under Cal. Penal Code § 459 qualified as "burglary of a dwelling" for purposes of the career-offender sentencing enhancement under U.S.S.G. §§ 4B1.1 and 4B1.2. The district court had relied on those documents to treat the prior conviction as a crime of violence, raising Snellenberger's advisory guideline range. The Ninth Circuit held that minute orders are not judicial records that may be consulted under Shepard v. United States, 544 U.S. 13 (2005), to determine the elements of a prior conviction via the modified categorical approach. The court therefore vacated the sentence and remanded for resentencing, rejecting the government's argument that minute orders should be treated like abstracts of judgment.
This case involved copyright owners Universal and Disney suing Sony, retailers, and an individual user over the Betamax VCR's ability to record copyrighted audiovisual broadcasts off public airwaves for later home viewing. The district court decided that neither the 1909 nor 1976 Copyright Act granted authors monopoly rights over private, non-commercial off-the-air home copying by individuals, so no infringement occurred and the corporate defendants bore no direct, contributory, or vicarious liability. The core reasoning emphasized the constitutional balance in Article I, Section 8, Clause 8 between incentivizing creative work through limited exclusive rights and ensuring broad public availability of arts and literature, concluding that Congress had not extended protection to this personal use. The court further found no unfair competition or interference with business relations, and noted that injunctive relief would be unavailable even if infringement had been established.
In Doe v. Gallinot, the plaintiff challenged provisions of California's Lanterman-Petris-Short Act governing involuntary civil commitment to mental institutions, claiming that the 'gravely disabled' standard was unconstitutionally vague and that the statutory process for 14-day certification lacked adequate due process protections. The court denied summary judgment on the vagueness claim but granted it on the due process claim, holding that the ex parte certification process without prompt judicial review violated constitutional requirements. The opinion reasoned that after the initial 72-hour emergency detention, due process mandates an independent probable cause hearing—conducted by someone outside the treating facility—within at most seven days to assess whether continued confinement is justified, emphasizing the need to minimize the risk of erroneous deprivation of liberty even when commitment is motivated by benevolent purposes. The court directed state officials to propose a plan implementing such review rather than specifying exact procedures itself.
This case involves a class action by conservatees and wards of the public guardian seeking a declaratory judgment that they are entitled to care in the least restrictive settings, an injunction against certain placement practices by the public guardian, and damages for alleged violations of state statutory duties and constitutional rights. The defendants moved for abstention from federal jurisdiction. The court granted abstention, holding that federal intervention would improperly interfere with the continuing jurisdiction of state probate courts over conservatorships and guardianships under the Younger doctrine, given the state's important interests in such proceedings. Abstention was also warranted under the Pullman doctrine because unsettled questions of state law regarding guardians' duties could resolve the federal constitutional claims without federal court involvement. The court reserved jurisdiction over any remaining federal issues after state adjudication.
Plaintiffs Arthur W. Carlsberg and related entities sued two SEC attorneys, alleging that the defendants intentionally violated their constitutional rights by actions taken during an investigation and civil enforcement action against a third-party company, Pre-Builder Land Corporation, including filing complaints, seeking injunctions without notice, making false statements, and advising others to stop payments on notes held by plaintiffs. The plaintiffs also asserted pendent state tort claims for abuse of process and interference with contractual relations. The court granted summary judgment to defendant Gatzek on all claims, treating the motion as one for summary judgment after considering matters outside the pleadings. The core reasoning was that the defendant, as a federal government attorney in a civil securities enforcement action, enjoyed absolute immunity from personal liability for acts integral to the judicial process under precedents like Bivens, Imbler, and Flood, which applied even to claims by non-parties incidentally affected; the court also found no due process violation from authorized SEC public announcements.