La Alliance for Human Rights v. County of Los Angeles
14 F.4th 947
| 9th Cir. | 2021Background
- LA Alliance for Human Rights and eight individual plaintiffs sued the City and County of Los Angeles challenging policies and inaction that they say allowed Skid Row encampments to proliferate, harming residents, businesses, and public safety.
- Plaintiffs sought a sweeping preliminary injunction requiring, among other things, escrow of $1 billion, offers of shelter or housing to all unhoused individuals in Skid Row within 180 days, clearance of encampments, and multiple audits and plans to remediate Skid Row.
- The district court granted a broad injunction after extensive factfinding tying Los Angeles’s homelessness crisis to structural racism and finding a likelihood of success on six claims (state-created danger, special relationship, race-based equal protection, substantive due process family-integrity, Cal. Welf. & Inst. Code § 17000, and the ADA).
- The Ninth Circuit panel held the injunction rested largely on unpled theories and extra-record materials; many of the district court’s findings relied on sources not properly judicially noticed and disputed factual claims.
- The court found Plaintiffs lacked Article III standing for all but the ADA claim brought by two wheelchair-using plaintiffs; those two had standing but failed to show likelihood of success on the ADA claim at the preliminary-injunction stage.
- The Ninth Circuit vacated the preliminary injunction and remanded, concluding the district court abused its equitable authority by issuing relief beyond the claims pleaded and by using improperly noticed/extratrecord evidence to fill gaps in standing and merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for race-based and due-process claims (state-created danger, special relationship, substantive due process, equal protection) | Plaintiffs argued systemic violations and harms to Skid Row residents/businesses gave rise to these claims and justified broad relief. | Defendants argued Plaintiffs did not plead race-based claims or show individual members (or LA Alliance members) who are Black or otherwise injured in ways required for these claims. | Court: No standing for these claims—Plaintiffs failed to show individual or associational standing; claims were largely unpled and based on extra-record theory. |
| Authority to grant relief on unpled theories and against un-named defendants | Plaintiffs embraced the district court’s broader structural-racism framing and sought comprehensive remedies. | Defendants argued equitable relief must be limited to the case/controversy pled; court cannot grant injunction based on unpled claims or novel legal theories. | Court: District court abused discretion by enjoining on claims and theories not pled; injunction exceeded equitable authority. |
| Use of extra-record materials and judicial notice in preliminary injunction factfinding | Plaintiffs relied on the district court’s consideration of historical and academic sources to support findings. | Defendants objected to reliance on extra-record materials and disputed facts not subject to judicial notice. | Court: District court improperly relied on independent research and materials not judicially noticed for their truth; this tainted standing and merits findings. |
| ADA claim re: obstructed sidewalks (two wheelchair plaintiffs) | Plaintiffs contended blocked sidewalks denied programmatic benefits of City sidewalks, so the City violated Title II; sought broad remedies (clearing, shelter offers). | City argued plaintiffs failed to show programmatic discrimination, concrete ADA violations as required, and failed to propose tailored reasonable accommodations. | Court: Two plaintiffs had standing, but plaintiffs failed to show likelihood of success at PI stage; relief was not tailored and district court abused discretion relying on extra-record evidence. |
Key Cases Cited
- Martin v. City of Boise, 920 F.3d 584 (9th Cir.) (discusses limits on criminalizing sleeping outside when no shelter available)
- Pac. Radiation Oncology, LLC v. Queen’s Med. Ctr., 810 F.3d 631 (9th Cir.) (district court cannot enjoin on claims not pled)
- Winter v. Nat. Res. Def. Council, 555 U.S. 7 (2008) (preliminary injunction standards)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (Article III standing requirements)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (redressability and standing principles)
- DeShaney v. Winnebago Cty. Dept. of Soc. Servs., 489 U.S. 189 (1989) (special-relationship/state-created danger doctrine limits)
- Friends of the Earth, Inc. v. Laidlaw Envt’l Servs., 528 U.S. 167 (2000) (standing and redressability; associational standing requirements)
- Kirola v. City & County of San Francisco, 860 F.3d 1164 (9th Cir.) (programmatic ADA injury and tailoring of remedies)
- Barden v. City of Sacramento, 292 F.3d 1073 (9th Cir.) (Title II/service program analysis)
- Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848 (9th Cir.) (district court abuses discretion when findings lack record support)