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Decision levers
AI-measured from their own opinions — each lever cites its cases
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In [3] Rawlinson's opinion holds no private right of action exists after examining specific text of 47 U.S.C. §§ 251(b)(5), 201(b), 206 and 207. North County Communications Corp… ↗
The case involved a parent (Pat Oman) suing Portland Public Schools and related officials on behalf of her disabled child (C.O.) under the Individuals with Disabilities Education Act (IDEA), alleging the district failed to provide a free appropriate public education through an appropriate individualized education program and seeking nominal damages, among other claims. The Ninth Circuit held that Oman’s IDEA-related cross-claims must be dismissed for lack of jurisdiction and reversed the district court’s ruling that the school district was liable for nominal damages under the IDEA and 42 U.S.C. § 1983. The court reasoned that the IDEA’s enforcement scheme—centered on procedural safeguards, administrative hearings, and equitable relief such as compensatory education—does not authorize claims for monetary damages, including nominal damages, a conclusion reinforced by Congress’s separate policies supporting competitive-admission magnet and charter programs. The court affirmed the district court’s judgment on all remaining counts.
The case involved homeowners Todd and Karen Brandt who sued their flood insurer, American Bankers Insurance Company of Florida, for breach of contract and bad faith under Washington law after a disputed claim payment from a 2007 flood. After the insurer failed to respond to the complaint served via the state insurance commissioner, the district court entered a default judgment exceeding $655,000. The district court later granted the insurer's motion to set aside the default and judgment under Federal Rule of Civil Procedure 60(b)(1) for excusable neglect, finding the failure to respond culpable but not intentional or in bad faith, and noting a meritorious defense plus curable prejudice. The Ninth Circuit affirmed, holding that a district court retains discretion to set aside a default judgment under Rule 60(b)(1) even with a culpability finding, as the excusable neglect inquiry is equitable and considers all relevant factors including a meritorious defense.
Michael Marlo sued United Parcel Service (UPS) for unpaid overtime, meal, and rest-period wages after being classified as an exempt executive and administrative employee under California’s Industrial Welfare Commission Wage Order No. 9. The district court initially certified a class of full-time supervisors but later decertified it on the ground that common issues of law or fact did not predominate over individual ones, as required by Federal Rule of Civil Procedure 23(b)(3). The Ninth Circuit affirmed, holding that the district court did not abuse its discretion because employee surveys and testimony revealed variations in job duties depending on facilities, managers, and customer bases, making class-wide proof unreliable.
The case involved Mexican plaintiffs who suffered severe eye injuries after cataract surgeries in Mexico using a allegedly defective viscoelastic product manufactured by defendant Advanced Medical Optics, a Delaware corporation headquartered in California; they sued in federal district court in California for product liability and related claims. The district court dismissed the action on forum non conveniens grounds, determining that Mexico was an available and adequate alternative forum, without imposing conditions on the dismissal. Plaintiffs appealed and also filed suit in Mexico, but the Mexican court declined jurisdiction. The Ninth Circuit held that while the district court's initial analysis was not erroneous based on the record at the time, subsequent events required reconsideration of whether Mexico remained an available forum, and thus vacated the dismissal and remanded for further proceedings.
Hossein Zeinali, an engineer of Iranian descent employed by Raytheon, was terminated after the Department of Defense denied his application for a security clearance, which the company had stated was required for his position. He sued under the California Fair Employment and Housing Act, alleging that Raytheon discriminated against him on the basis of race and national origin by retaining non-Iranian engineers who lacked clearances. Raytheon argued that federal courts lack jurisdiction under Egan and that Zeinali failed to meet his evidentiary burden under McDonnell Douglas. The Ninth Circuit held that jurisdiction exists because the claim challenges the evenhanded application of the company's policy rather than the merits of the government's clearance decision, and reversed the district court's dismissal after finding sufficient evidence that the policy may have been applied in a discriminatory manner.
The case involved Kenneth Edward Watson appealing the district court's revocation of his supervised release and imposition of a three-year prison sentence after he failed to comply with reporting requirements starting in 1995. Watson argued that his eleven arrests by Minnesota state authorities between 1996 and 2007 ended his fugitive status, so his term of supervised release had expired long before his 2009 federal arrest and the court lacked jurisdiction. The Ninth Circuit held that the state arrests provided neither actual nor constructive knowledge to federal authorities of his whereabouts, as they involved only state crimes and officials with no indication of federal access to the information. The court therefore concluded that fugitive tolling continued until Watson's federal arrest, affirming the district court's jurisdiction and sentence.
