Release of American Journalist Shelly Kittleson

Secretary of State Marco Rubio announced the release of American journalist Shelly Kittleson, who was kidnapped by Kata'ib Hizballah near Baghdad, Iraq. The State Department credited collaboration with the FBI, Department of War, Iraqi Supreme Judicial Council, and other agencies for securing her release.

Olson v. FCA US, LLC - Arbitration Enforcement by Non-Signatory

The Ninth Circuit affirmed the district court's denial of FCA US LLC's motion to compel arbitration in a consumer lease dispute. The court held that non-signatories to an arbitration agreement generally cannot enforce the agreement against a signatory party, rejecting FCA's attempt to invoke a delegation clause in a lease agreement it was not a party to. The ruling establishes that automobile manufacturers cannot compel arbitration through delegation clauses in dealership contracts unless an exception applies.

USA v. Verhonich - Jet Ski Misdemeanor, NPS Violation

The Ninth Circuit affirmed Bryce Verhonich's misdemeanor conviction for negligent jet ski operation in National Park Service waters, where a passenger drowned. The court upheld his six-month custody and two-year probation sentence. The panel ruled for the first time that failure to wear a personal flotation device and failure to attach a safety lanyard may both be considered as evidence of negligent vessel operation under 36 C.F.R. § 3.8(b)(8).

Thrower v. Academy Mortgage Corp. - Postjudgment Interest on FCA Attorneys' Fees

The 9th Circuit affirmed the district court's order holding that postjudgment interest on attorneys' fees awarded under 31 U.S.C. § 3730(d)(2) in a False Claims Act qui tam action accrues from the date of the order awarding fees, not from the earlier order confirming settlement. The court held that under 28 U.S.C. § 1961(a), a 'money judgment' requires identification of parties and a definite, certain designation of the amount owed, and a settlement confirmation order without a designated fee amount does not qualify.

Thrower v. Academy Mortgage Corp. - Attorneys' Fees Enhancement

The Ninth Circuit reversed the Northern District of California's award of attorneys' fees with a 1.75 multiplier in a qui tam False Claims Act action against Academy Mortgage Corp. The panel held that district courts abuse their discretion by awarding fee enhancements above the lodestar calculation except in rare and exceptional cases supported by specific evidence that the lodestar is unreasonably low.

Fresenius Medical Care Orange County, LLC v. Bonta - First Amendment Challenge to California AB 290

The 9th Circuit affirmed in part and reversed in part the district court's summary judgment in Fresenius Medical Care Orange County, LLC v. Bonta, Nos. 24-3654 and 24-3700. The panel held that California's Assembly Bill 290 provisions—the Reimbursement Cap and Patient Disclosure Requirement—violate the First Amendment rights of dialysis providers and the American Kidney Fund. The Reimbursement Cap was found not narrowly tailored to California's interest in preventing insurance risk pool distortion, and the Patient Disclosure Requirement fell with it since California's defense depended solely on the invalid Reimbursement Cap.

Fresenius Medical Care Orange County LLC v. Bonta - First Amendment Challenge to California AB 290

The Ninth Circuit affirmed in part and reversed in part the district court's summary judgment in a First Amendment challenge to California Assembly Bill 290 (AB 290), which regulates dialysis providers' relationships with nonprofit health insurance premium assistance charities. The court held that the Reimbursement Cap and Patient Disclosure Requirement provisions are unconstitutional under the First Amendment because they burden the association rights of dialysis providers and the American Kidney Fund without being narrowly tailored to California's asserted government interest in preventing insurance risk pool distortion.

Fresenius Med. Care Orange County, LLC v. Bonta - First Amendment Challenge to California AB 290 Dialysis Reimbursement Limits

The Ninth Circuit partially affirmed and partially reversed the district court's summary judgment in consolidated appeals challenging California Assembly Bill 290 (AB 290), which regulates dialysis providers' relationships with nonprofit health insurance premium assistance charities. The court held that the Reimbursement Cap and Patient Disclosure Requirement violate the First Amendment rights of dialysis providers and the American Kidney Fund, finding California's asserted interest in preventing insurance risk pool distortion does not save provisions that are not narrowly tailored.

In re Google LLC - Mandamus Granting Venue Transfer to Northern District of California

The Fifth Circuit granted Google LLC's petition for writ of mandamus, reversing the Eastern District of Texas's denial of venue transfer under 28 U.S.C. § 1404(a). The appellate court held that the district court misapplied the law in balancing transfer factors, finding most witnesses and sources of proof were located in California. The court directed transfer of Branch Metrics' Sherman Act antitrust suit against Google to the Northern District of California.

Oregon HB4037 - Housing Programs Reform

Oregon Governor signed HB4037 on April 7, 2026, enacting comprehensive housing reforms including adjusted revolving loan terms for affordable housing projects, limited building permit plan review for housing with two or fewer dwelling units, and established local government land use approval processes for housing subject to clear and objective standards. The Act also creates landlord and tenant responsibilities for residential tenancies destroyed by natural disasters and requires state agencies to prioritize housing providers when transferring surplus real property.