Frank Mahuka , Jr. v. William Aila, Jr.
20-16369
| 9th Cir. | Mar 24, 2022Background
- Plaintiffs Frank Mahuka, Jr. and Joakim Mahuka, proceeding pro se, brought a 42 U.S.C. § 1983 action asserting Takings Clause and due process violations related to Hawaiian Homes Commission Act (HHCA) eligibility/leases.
- The district court dismissed claims against the United States for failure to state a plausible claim and because challenges to HHCA eligibility implicate the United States as an indispensable party.
- The district court dismissed claims against State defendants for lack of Article III standing, finding plaintiffs did not allege a concrete, particularized injury.
- Plaintiffs’ opposition to the State defendants’ motion was treated as a motion for reconsideration of the dismissal of the United States; the district court denied reconsideration for failure to present a basis for relief.
- The Ninth Circuit reviewed the dismissals de novo and affirmed the district court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiffs stated a plausible claim against the United States / may challenge HHCA eligibility | Mahuka(s) argued their §1983 Takings and due process claims could proceed against the United States and challenge HHCA eligibility | Plaintiffs failed to plead sufficient facts; challenges to HHCA eligibility require the United States as an indispensable party | Dismissed: plaintiffs did not allege a plausible claim and could not press HHCA-eligibility challenges without the United States as a party |
| Whether plaintiffs had Article III standing to sue State defendants | Mahuka(s) claimed concrete injury from defendants’ actions under Takings/Due Process | State defendants argued no concrete, particularized injury was alleged (Spokeo) | Dismissed for lack of standing: injury-in-fact not adequately alleged |
| Whether the district court abused its discretion by denying reconsideration | Plaintiffs contended the opposition should not be treated as reconsideration and sought relief | District court held plaintiffs presented no grounds for reconsideration | Denial affirmed: no abuse of discretion; plaintiffs failed to show basis for relief |
| Whether the district court failed to liberally construe pro se pleadings / plaintiffs’ motion to strike the U.S. brief | Plaintiffs argued the court did not sufficiently construe pro se filings and sought to strike the U.S. answering brief | Court applied liberal construction doctrine but required factual allegations; motion to strike lacked merit | Affirmed: pleadings were properly construed; arguments meritless and motion to strike denied |
Key Cases Cited
- Cervantes v. Countrywide Home Loans, 656 F.3d 1034 (9th Cir. 2011) (de novo review and Rule 12(b)(6) plausibility standard)
- Mayfield v. United States, 599 F.3d 964 (9th Cir. 2010) (review of dismissal for lack of standing)
- Hebbe v. Pliler, 627 F.3d 338 (9th Cir. 2010) (pro se pleadings must still allege facts sufficient to state a plausible claim)
- Arakaki v. Lingle, 477 F.3d 1048 (9th Cir. 2007) (United States is an indispensable party to HHCA eligibility challenges)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (injury-in-fact must be concrete and particularized for Article III standing)
- Sch. Dist. No. 1J, Multnomah County, Or. v. ACandS, Inc., 5 F.3d 1255 (9th Cir. 1993) (standards for reconsideration)
- Padgett v. Wright, 587 F.3d 983 (9th Cir. 2009) (appellate court will not consider issues not raised in the opening brief)