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

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-03 Docket: 1:21-cv-00248-LEK-KJM The ninth-circuit affirmed the district court’s grant of summary judgment to police officers and dismissal of claims against the City and County of Honolulu in a civil rights action brought under 42 U.S.C. § 1983. The court held that Officer Koanui’s statements characterizing the plaintiff’s retention of her former employer’s business phone as “borderline extortion” were not motivated by retaliation for her attempt to file a criminal complaint, as there was no but-for causal link between her protected activity and the officer’s conduct under *Nieves v. Bartlett*. The court further determined that the equal protection claim failed because undisputed differences in the investigative posture of the respective complaints provided a rational basis for treating the parties differently. Consequently, the conspiracy claims against the officers and the municipal liability claim against Honolulu were also dismissed due to the absence of an underlying constitutional violation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.