The case involved the federal government's appeal of a 30-month sentence imposed on Jose Leal-Vega after his guilty plea to illegal reentry following deportation under 8 U.S.C. § 1326. The district court had applied only a four-level sentencing enhancement instead of the 16-level enhancement under U.S.S.G. § 2L1.2 for a prior 1999 California conviction under Health & Safety Code § 11351 for possession of a controlled substance for sale. The Ninth Circuit held that § 11351 does not categorically qualify as a "drug trafficking offense" because it covers substances broader than those listed in the federal Controlled Substances Act. However, applying the modified categorical approach, the court found that Leal-Vega's conviction record specified tar heroin, which is covered by federal law, making the 16-level enhancement applicable, and remanded for resentencing.
The case involved Galo Alejandro Ordonez, who after his 1994 drug conviction sought return of personal property seized by the government during his 1993 arrest under Federal Rule of Criminal Procedure 41(g). Some items were returned, but others were lost or destroyed, leading Ordonez to request money damages as equitable relief. The district court dismissed the claim, and the Ninth Circuit affirmed, holding that sovereign immunity barred monetary awards because Rule 41(g) provides no express waiver of immunity and does not independently authorize damages. The court reasoned that even though the government's loss of property left the plaintiff without a remedy, equitable considerations alone cannot override the requirement for a clear congressional waiver of immunity. Jurisdiction was based on 28 U.S.C. § 1291, and the decision relied on precedent interpreting similar rules as not waiving immunity.
The case involved Huping Zhou, a former UCLA Health System research assistant, who accessed patient medical records without authorization after his employment was terminated. The government charged him under HIPAA's criminal provision, 42 U.S.C. § 1320d-6(a)(2), for knowingly obtaining individually identifiable health information in violation of the statute. Zhou moved to dismiss the information, arguing it failed to allege that he knew his conduct was illegal, but the district court denied the motion, and Zhou entered a conditional guilty plea. The Ninth Circuit affirmed, holding that the plain language of the statute requires only that the defendant knowingly obtained the health information and did so in violation of HIPAA, without needing proof that the defendant knew the act was unlawful. The court rejected arguments based on other criminal statutes, civil penalty provisions, and the rule of lenity, finding the text unambiguous.
Janet Wood, a single City of San Diego retiree, sued the City under Title VII alleging that its surviving spouse pension benefit option discriminates on the basis of sex because the City pays more in aggregate benefits to married retirees (who are disproportionately male) than to single retirees like her, who receive only a refund or increased monthly payment. The district court dismissed her disparate treatment and disparate impact claims. The Ninth Circuit affirmed, holding that the disparate treatment claim failed for lack of any allegation of intentional discrimination and that the disparate impact claim failed as a matter of law under Supreme Court precedent in City of Los Angeles Department of Water & Power v. Manhart, which rejected similar challenges to gender-neutral pension structures as based on factors other than sex under the Equal Pay Act and Bennett Amendment. The court noted that Wood had Article III standing but that this did not salvage the claim.
The case involved Paul Edwards, an additional cardholder on a Wells Fargo Visa account opened by Hamid Maghamfar, who disputed several merchant charges under $1,000 and sought resolution from the bank under the Fair Credit Billing Act (part of the Truth in Lending Act) and Regulation Z. Wells Fargo initially handled the disputes but later stopped responding to Edwards directly, instead contacting only the Maghamfars as the account obligors, leading Edwards to sue for damages. The Ninth Circuit affirmed summary judgment for Wells Fargo, holding that the bank's billing dispute resolution duties apply only to the primary obligor on the account, not to additional authorized cardholders who are not liable for payment. The court reasoned that the statute refers to obligations owed to obligors, and Regulation Z's references to periodic statements, withholding payment, and collection efforts would be nonsensical if applied to non-obligor users, even though they might know details of the transactions.
This case involved tax-exempt labor unions that filed their required informational returns late with the IRS, resulting in penalties calculated by a statutory formula based on delay length and gross receipts. The unions sought relief through administrative hearings and court appeals, arguing reasonable cause for the delays or that the penalties should be reduced, but the IRS rejected these claims. The district court found no reasonable cause yet reduced the penalties as a matter of discretion, leading to an IRS appeal. The Ninth Circuit reversed, holding that the relevant tax statutes provide no authority for courts to discretionarily reduce penalties in the absence of reasonable cause, leaving only the full statutory amount or none at all. The court affirmed the denial of costs to the unions and remanded for affirmation of the original penalties.