Case Explained: FIRSOV V. CITY AND COUNTY OF HONOLULU, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-04 Docket: 1:23-cv-00429-LEK-KJM The ninth-circuit affirmed the district court’s grant of summary judgment to the City and County of Honolulu on all of plaintiff Evgeny Firsov’s claims arising from the denial of his REAL ID Driver’s License application. The court held that Firsov failed to show prejudice from the district court’s decision to grant summary judgment before ruling on his motion to compel, as the dispositive grounds for the City’s victory did not depend on the evidence sought. Regarding the merits, the court ruled that none of Firsov’s claims provided a basis for liability because he lacked a private right of action under the REAL ID Act of 2005, Section 19-149-2 of the Hawai’i Administrative Rules, Article 27 of the 1951 Convention Relating to the Status of Refugees, Article 26 of the 1966 International Covenant on Civil and Political Rights, or Sections 2 and 3 of the 1967 United Nations Protocol Relating to the Status of Refugees. The court further held that his claim under Section 274B of the Immigration and National Act failed because it applies only to employment discrimination, not DMV licensing. His Equal Protection Clause claim failed because the City’s actions were compelled by federal law rather than being the “moving force” behind the injury, and any local policy lacked discriminatory intent. Finally, his Civil Rights Act claims failed because Title VI does not cover immigration status discrimination, Title III suits are limited to the Attorney General, and Title II does not authorize private damages suits. The practical consequence is that the judgment for the City stands and Firsov’s appeal is dismissed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.