1

This question was inspired by the recent decision in Health Freedom Defense Fund v. Carvalho (if that's the right way to refer to it) but I intend the question to be more general if it's possible to generalize.

To quickly summarize the case as I understand it, a school district had a COVID-19 vaccine mandate, some employees sued, and the District Court dismissed their suit. Now the 9th Circuit Court has vacated the dismissal and remanded the case to the District Court. The key points of the decision are 1) the case is not moot because the school district appears to have withdrawn the mandate in the expectation of an unfavorable legal outcome; and 2) the 1905 Supreme Court case on which the lower court based its decision is not applicable for reasons that I don't think are relevant to the question.

When a Circuit Court vacates and remands a decision like this, the media rant and celebrate. But what does it actually mean for the average person? As I understand it, the District Court could still issue the same decision with some other legal reasoning. Until they do, does the case have any bearing on anyone's rights other than perhaps the plaintiffs'? And if so, does it have any significance outside the 9th Circuit?

Improve this question
0

3 Answers 3

Reset to default
5

It means the order of the lower court is essentially erased (this is the vacatur). That district court order no longer has any effect: not for the parties; not for anyone.

Second, it means that the case has been returned to the district court to resume exercising its jurisdiction to deal with the case. The reasons of the Circuit Court of Appeal provide new guidance for the lower court as to what the correct law is. Those reasons also set the law throughout the circuit.

More simply:

  • the original order is nullified
  • the district court has to decide the issue anew, consistent with the law that was announced by the court of appeal

It's not necessarily back to square one. There may be costs consequences, and perhaps evidence previously admitted not being having to be reintroduced, or previous evidentiary rulings that go unchanged. Although in this particular case, as ohwilleke notes, the district court had essentially gotten nowhere with the case yet: it was dismissed at a very early stage, so it will just continue on from there.

Improve this answer
5
  • and most importantly: This is not a new case, but a continuation of the old one.
    – Trish
    Commented Jun 15 at 5:54
  • So for other people in similar situations, and even for the plaintiffs, it's basically as if the case has not been heard yet?
    – Merry Misanthrope
    Commented Jun 15 at 16:48
  • @MerryMisanthrope a district court case has no effect for people who aren't parties to the case, so it doesn't matter to them whether the case has been heard yet. (But vacating the decision erases only the decision, not the entire case.) The appeal, however, could set a precedent that is relevant to anyone with a pending (or future) case in the circuit. The disposition of the district court case itself isn't relevant, only the statement of the law.
    – phoog
    Commented Jun 15 at 16:57
  • 1
    @phoog So the disposition of the case itself doesn't matter, but Circuit Court's reasoning for why Jacobson v. Massachusetts doesn't apply sets a precedent in the 9th Circuit?
    – Merry Misanthrope
    Commented Jun 15 at 17:05
  • @MerryMisanthrope yes. For (very contrived) example, a court might rule that vehicle searches must be conducted while wearing a green hat to be permissible under the fourth amendment. In one case, a conviction might be reversed because the officer had been wearing a blue hat, while in another case a conviction might be upheld because the officer had been wearing a green hat. The disposition of the cases is opposite, but the newly articulated principle of law is the same.
    – phoog
    Commented Jun 17 at 9:25
1

Vacating a decision means to cancel it. "For the average person," at least, "vacate" is synonymous with "cancel" or "overturn."

Remanding the case to the lower court means to send it back down to the lower court for further action. The higher court often instructs the lower court very precisely as to the nature of that action (for example, to dismiss the case with prejudice). They may also give a less specific instruction, essentially to reconsider the case in light of the higher court's ruling (for example, they may say something like "for further proceedings not inconsistent with this opinion").

Improve this answer
1

In this particular case, where the case was dismissed pursuant to a motion to dismiss, which happens at the very outset of the litigation, this means that the normal lawsuit process will resume.

The defendant will file an answer to the complaint, a trial date and pre-trial deadlines and discovery rules will be put in place, there will be pre-trial depositions, production of documents, and interrogatories, there may be a later motion for summary judgment considering the substance of the appellate court ruling by either side, there will probably be a court required mediation session, and if the case isn't resolved at that point, there will be a trial, and possibly another appeal. This process will take nine months to a couple of years.

Improve this answer

You must log in to answer this question.

Not the answer you're looking for? Browse other questions tagged .