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Stephen Reinhardt
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Stephen Roy Reinhardt (born Stephen Roy Shapiro;[1] March 27, 1931 – March 29, 2018)[2] was a United States circuit judge of the United States Court of Appeals for the Ninth Circuit, with chambers in Los Angeles, California. He was the last federal appeals court judge in active service to have been appointed to his position by President Jimmy Carter.[a]

Key Information

Early life and career

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Reinhardt was born Stephen Roy Shapiro into a Jewish family in New York City,[3] to lawyer Samuel Shapiro, and Silvia Handelsman.[4] Reinhardt changed his name after his mother divorced his father and married film director and producer Gottfried Reinhardt.[1] Reinhardt graduated from University High School in Los Angeles. He enrolled in Pomona College and graduated three years later with a Bachelor of Arts degree in government in 1951. In 1954, he received a Bachelor of Laws from Yale Law School.[5]

After law school, Reinhardt worked at the legal counsel's office for the United States Air Force as a lieutenant in Washington, D.C. Two years later, he clerked for United States District Judge Luther Youngdahl, a former governor of Minnesota, of the United States District Court for the District of Columbia. He then entered private practice, working for the law firm O'Melveny & Myers from 1958 to 1959 practicing entertainment law. After two years at O'Melveny, he began working at a small firm in Los Angeles that became Fogel, Julber, Reinhardt, Rothschild & Feldman, specializing in labor law.[5]

Reinhardt served as a member of the United States Commission on Civil Rights, California Advisory Committee from 1962 to 1974 and was its vice chairman from 1969 to 1974. He also served as member of the Democratic National Committee and as an unpaid advisor to former Los Angeles mayor Tom Bradley and California governor Jerry Brown. In 1975, he was appointed to the Los Angeles Police Commission, which he chaired from 1978 until his judicial confirmation in 1980.[5]

Federal judicial service

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Reinhardt was nominated by President Jimmy Carter on November 30, 1979, to the United States Court of Appeals for the Ninth Circuit, to a new seat authorized by 92 Stat. 1629. He was confirmed by the United States Senate on September 11, 1980, and received his commission on September 11, 1980. His service terminated on March 29, 2018, due to his death.[5]

Other service

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Reinhardt continued his public service as Secretary of the 1984 Los Angeles Olympic Organizing Committee and as a member of the Board of Directors of the Los Angeles Amateur Athletic Foundation.

Reinhardt administered the oath of office to former Los Angeles Mayor Antonio Villaraigosa on July 1, 2005.[6]

Personal life

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Reinhardt's mother divorced his father and married movie director Gottfried Reinhardt, the son of director Max Reinhardt. Stephen Reinhardt's first wife was Mary Wainwright, whom he married in 1956 and with whom he had three children. They divorced after nearly 25 years.[7] His second wife was Maureen Kindel, who was president of the Los Angeles Board of Public Works in the 1980s.[8] Later Reinhardt married Ramona Ripston, who was Executive Director of the ACLU of Southern California until her February 2011 retirement. They remained married until his death.[9][4]

Death

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Reinhardt died in Los Angeles on March 29, 2018, from a heart attack.[10]

Chief Judge Sidney Runyan Thomas issued the following statement upon learning of Reinhardt's death:[11]

All of us here at the Ninth Circuit are shocked and deeply saddened by Judge Reinhardt’s death. We have lost a great friend and colleague. As a judge, he was deeply principled, fiercely passionate about the law and fearless in his decisions. He will be remembered as one of the giants of the federal bench. He had a great life that ended much too soon.

Posthumous controversy

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Reinhardt was involved in a controversy after he died. Eleven judges of the Ninth Circuit heard oral argument in the case of Yovino v. Rizo. Reinhardt wrote an opinion on behalf of himself and five other judges, which was issued by the court 11 days after he died. A footnote at the beginning of the opinion stated: “Prior to his death, Judge Reinhardt fully participated in this case and authored this opinion. The majority opinion and all concurrences were final, and voting was completed by the en banc court prior to his death.”[12]

The case was appealed to the Supreme Court, which vacated Reinhardt's opinion. The Supreme Court stated:

As for judicial practice, we are not aware of any rule or decision of the Ninth Circuit that renders judges’ votes and opinions immutable at some point in time prior to their public release. And it is generally understood that a judge may change his or her position up to the very moment when a decision is released. . . . Because Judge Reinhardt was no longer a judge at the time when the en banc decision in this case was filed, the Ninth Circuit erred in counting him as a member of the majority. That practice effectively allowed a deceased judge to exercise the judicial power of the United States after his death. But federal judges are appointed for life, not for eternity.[12]

The Supreme Court remanded the case for further proceedings.[13]

In 2020, after Judge Reinhardt's death, a staff attorney at the Center for Death Penalty Litigation in Durham, North Carolina testified before the Subcommittee on Courts, Intellectual Property, and the Internet that Judge Reinhardt had sexually harassed her while she worked for him as a law clerk; her testimony described her efforts to report the harassment.[14]

Judicial philosophy

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Reinhardt was known as one of the most liberal judges on the courts of appeals. His decisions were "reversed more often than most" judges before the Supreme Court.[15] In 2003, Reinhardt admitted that he "was a liberal from a very young age." "I think I was born that way", he said.[16] However, he did not believe that a Supreme Court reversal meant that his opinion was wrong or that he did not follow the law. "The Supreme Court changes the law regularly. And this Supreme Court - which is the most activist Court there has ever been - is constantly changing the law. So if you really are faithful to the law, you're likely to get reversed because it [the Court] has cut back on rights."[16] When pressed on the issue of his high reversal rate, he once stated "They can't catch 'em all".[17]

His reversal rate did not affect his status as a feeder judge—between 2009 and 2013, he placed six of his clerks on the Supreme Court, tied for the tenth highest number during the same time period.[18]

One of Reinhardt's former clerks, Cornell law professor Michael Dorf, said that when Reinhardt "believes himself clearly bound by Supreme Court precedent with which he disagrees, he states his disagreement but follows the precedent." Dorf accounts for Reinhardt's reversal rate by stating that "Reinhardt resolves cases under existing precedent as he believes those precedents should be read, without regard to whether five or more Justices of the Supreme Court are likely to reverse him."[19]

Reinhardt rejected originalism, and believed the Constitution could bring justice to everyone, especially the underprivileged. Reinhardt was also a cynic and a pragmatist as well as a liberal. In May 2017, in the legal opinion of Magana Ortiz v. Sessions, Reinhardt admitted he could not stop a deportation, and said he had to allow it as a judge, although he would not as a citizen. Reinhardt also criticized the Trump administration in the opinion.[20]

Examples of opinions that reversed Reinhardt's opinions include:

Notable opinions

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The following are some of his more notable judicial opinions:

  • Cardoza-Fonseca v. U.S. Immigration and Naturalization Service, 767 F.2d 1448 (9th Cir. 1985).
  • The INS had conflated two different routes for seeking asylum and had improperly rejected an application made under one route based on the requirements of the second. This decision was upheld by the Supreme Court.
  • Coleman v. Risley, 839 F.2d 434 (9th Cir. 1988).
  • Standard to obtain asylum.
  • Yniguez v. Arizonans for Official English, 939 F.2d 727 (9th Cir. 1991), adopted en banc, 69 F.3d 920 (9th Cir 1995).
  • The English-only provision in the Arizona constitution was overly broad and violated the First Amendment right of free speech. This decision was vacated by the Supreme Court as moot because plaintiff Yniguez had voluntarily left the employment of the State of Arizona the day after the appeal was filed. 520 US 43. Justice Ginsburg's unanimous opinion for the Court also took a swipe at the Ninth Circuit for failing to certify this question to the state courts, holding that "A more cautious approach was in order. In addition, footnote 11 of Justice Ginsburg's opinion chided the Ninth Circuit for failing to recognize that state courts are not bound by decisions of federal courts (except the Supreme Court), even on questions of federal law.
  • Sanders v. Ratelle, 21 F.3d 1446 (9th Cir. 1994).
  • The Sixth Amendment right to counsel can be infringed if counsel has a conflict of interest, even if the defendant has waived the conflict.
  • Compassion in Dying v. Washington, 79 F.3d 790 (9th Cir. 1996) (en banc).
  • A statute prohibiting doctors from prescribing life-ending medication for the terminally ill violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court reversed the Ninth Circuit in Washington v. Glucksberg (1997).
  • Ma v. Reno, 208 F.3d 815 (9th Cir. 2000).
  • An alien cannot be held indefinitely in detention in the absence of a repatriation agreement with his or her country of origin.
  • The right to bear arms is a collective right, not an individual right. This ruling was overruled by the Supreme Court in D.C. v. Heller (2008).
  • Forfeiture of the shark fins was denied on the grounds that, although according to the Shark Finning Prohibition Act of 2000, any shark fins found aboard a fishing vessel without a corresponding shark carcass may be deemed the product of illegal harvesting, the vessel from which the fins were seized was not in fact a fishing vessel within the meaning of the act. The fins had been harvested by, and bought from, other vessels.
  • In The Matter of Brad Levenson (2009)[22]
  • In his role as Chair of the Ninth Circuit’s Standing Committee on Federal Public Defenders, Reinhardt ruled that the application of the Defense of Marriage Act in denying health insurance benefits to Levenson's same-sex spouse violated the Due Process Clause of the Fifth Amendment.
  • Writing for the majority, Reinhardt held that Proposition 8 violated the Equal Protection Clause because California had no rational basis for withdrawing the right to marry from homosexual men and women.
  • Cooper v. Brown, 565 F.3d 581 (2009).
  • Reinhardt wrote a dissenting opinion, where he suggested the Ninth Circuit disclose the names of judges who vote for and against en banc rehearing of cases.[24]
  • Hernandez v. Chappell (December 29, 2017)
  • Reinhardt ruled that Hernandez was mentally ill and therefore could not be executed.[25] Overturned by the Ninth Circuit in 2019.[26]

Awards

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Reinhardt received the following awards:

  • 1987 Appellate Judge of the Year by the California Trial Lawyers Association
  • 1993 St. Thomas More Medallion Award by Loyola Law School
  • 1993 Donald Wright Award by the California Attorneys for Criminal Justice
  • 1995 Appellate Justice of the Year by the Consumer Attorneys Association of Los Angeles
  • 1998 Champion of Justice: Legal Award by the National Association of Criminal Defense Lawyers
  • 2004 Award for Judicial Excellence by the Idaho Association of Criminal Defense Lawyers
  • 2004 Meritorious Service Award by the University of Oregon Law School[27]

See also

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Notes

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References

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Revisions and contributorsEdit on WikipediaRead on Wikipedia

Stephen Reinhardt

View on Grokipedia
from Grokipedia
Stephen Roy Reinhardt (March 27, 1931 – March 29, 2018) was an American jurist who served as a Circuit Judge on the Court of Appeals for the Ninth Circuit from 1980 until his death. Nominated by President and confirmed by the , he held chambers in after a career in private practice there following education at and . Reinhardt's judicial tenure, spanning nearly 38 years, featured frequent dissents and majority opinions emphasizing individual rights against state power, particularly in cases where he condemned executions as unconstitutional barbarism and criticized the for procedural lapses. He contributed to rulings striking down restrictions on physician-assisted dying and participated in decisions invalidating California's Proposition 8, advancing recognition later affirmed by the . While lauded by advocates for safeguarding the powerless through rigorous scrutiny of government actions, Reinhardt faced accusations of from critics who contended his outcomes prioritized ideological preferences over textual fidelity and precedent, as seen in pointed exchanges with colleagues like Kozinski. His unyielding style and productivity, including deep involvement in pro se prisoner petitions, underscored a rooted in Warren Court-era expansion of rights, though often reversed or critiqued by higher courts.

Early Life and Education

Childhood and Name Change

Stephen Roy Shapiro was born on March 27, 1931, in to Samuel Shapiro, a , and Silvia Handelsman, members of a Jewish family. His early years unfolded in the urban setting of New York amid the and the onset of , though specific details of his childhood experiences remain limited in public records. Shapiro's parents divorced when he was young, after which his mother remarried in 1942 to Gottfried Reinhardt, a , director, and who was the son of the renowned Austrian theater . In the early 1940s, following this remarriage, Stephen adopted the surname Reinhardt, aligning with his mother's new family name; no primary accounts detail additional personal motivations for the change beyond this familial shift.

Academic and Military Background

Reinhardt earned a degree in government from in , graduating in 1951. He then pursued legal studies at , receiving a (LL.B.) in 1954. Following graduation, Reinhardt enlisted in the United States Air Force, serving from 1954 to 1956 as a in the legal counsel's office in , where he handled administrative legal duties during the post-Korean War period. Following his clerkship with a federal district judge in Washington, D.C., from 1956 to 1957, Stephen Reinhardt relocated to Los Angeles and entered private practice. He was admitted to the California Bar in 1958. Initially, Reinhardt joined the firm O'Melveny & Myers, where he practiced entertainment law from 1958 to 1959. In 1959, Reinhardt transitioned to a smaller Los Angeles firm specializing in labor , which later became known as Fogel, Julber, Reinhardt, Rothschild & Feldman. He became a partner in the firm and continued in private practice there until 1980. During this period, his work centered on labor disputes, representing unions and employees in negotiations and litigation.

Civic and Political Engagement

Prior to his judicial appointment, Reinhardt engaged in various civic roles in , beginning with service on the California Advisory Committee of the Commission on Civil Rights from 1962 to 1974, where he contributed to examinations of and issues in the state. He also served as president of the Los Angeles Board of and Parks Commissioners, overseeing public access to recreational facilities amid urban growth pressures in the late and early . In 1975, Reinhardt joined the Los Angeles Police Commission, ascending to in 1977 and president in 1978, positions he held until 1980; during this tenure, he participated in oversight of the , including efforts to address departmental reforms following civil unrest and allegations of misconduct. These roles positioned him at the intersection of and community welfare, focusing on accountability in and equitable . Reinhardt's political involvement aligned closely with Democratic causes, including serving as chief counsel to the Los Angeles County Federation of Labor, where he represented union interests in negotiations and advocacy during the 1960s and 1970s. He acted as an informal adviser to Los Angeles Mayor Tom Bradley, the city's first African American mayor elected in 1973, and provided counsel to Governor on state matters, reflecting his strategic engagement in Democratic Party infrastructure and support for labor-aligned policies benefiting working-class constituencies. Through these affiliations, Reinhardt demonstrated early commitment to advancing protections for laborers and underrepresented groups via institutional channels rather than electoral campaigns.

Judicial Appointment and Tenure

Nomination by Jimmy Carter

President nominated Stephen Reinhardt on November 30, 1979, to the United States Court of Appeals for the Ninth Circuit, to fill a new seat authorized by 92 Stat. 1629. This nomination occurred toward the end of Carter's presidency, amid efforts to staff the federal judiciary before the 1980 election and despite a backlog of circuit court vacancies that delayed many confirmations. Reinhardt, a Los Angeles-based attorney with experience in private practice and Democratic political campaigns, underwent standard vetting through the Department of Justice and Judiciary Committee review. The confirmation process advanced without notable public opposition or extended hearings, reflecting the Democratic-majority 's alignment with judicial selections during the 96th Congress. The confirmed Reinhardt on September 11, 1980, and he received his commission that same day, enabling him to take office prior to electoral loss to on November 4. This timing positioned Reinhardt among the final appointees of administration, which ultimately secured 262 federal judgeships despite the one-term limit.

Service on the Ninth Circuit Court of Appeals

Stephen Reinhardt received his commission as a United States Circuit Judge for the Ninth of Appeals on September 11, 1980, following nomination by President on November 30, 1979, and Senate confirmation on the same date. With chambers in , he maintained active status on the court, which has jurisdiction over federal appeals from nine western states, , , , and the , until his death on March 29, 2018, from a heart attack, resulting in a tenure of over 37 years. Reinhardt participated in the adjudication of thousands of appeals across diverse subject matters, including , environmental regulation, , and civil litigation, as part of three-judge panels typical for the circuit's operations. The Ninth Circuit, known for its high volume of cases—often exceeding 12,000 filings annually during his service—routinely assigned judges to such panels to manage the workload efficiently. He also engaged in proceedings, where the full court or a limited panel of eleven judges rehears significant or conflicting panel decisions, a mechanism frequently employed by the Ninth Circuit to address circuit splits and complex issues. In addition to his adjudicative duties, Reinhardt held administrative responsibilities, including serving as chair of the Ninth Circuit's Standing Committee on Federal Public Defenders, which oversees the provision of legal representation in federal criminal cases. He did not take or retire prior to his death, continuing full participation in the court's caseload without reduction in duties.

Judicial Philosophy

Commitment to Protecting the Powerless

Reinhardt articulated a judicial philosophy rooted in the judiciary's duty to shield vulnerable populations from majoritarian overreach, emphasizing constitutional safeguards for minorities and the disenfranchised. In his 1968 article "Riots, Racism, and the Courts," he contended that the legal system had eroded trust among through decisions perceived as indifferent to , calling on lawyers and judges to actively restore belief in judicial fairness. This commitment reflected his view of courts as essential bulwarks against systemic biases favoring the powerful. He frequently portrayed the federal judiciary, particularly the , as succumbing to majoritarian pressures that prioritized majority interests over minority protections. In a 1992 address, Reinhardt lambasted what he termed the Court's "majoritarian" orientation, arguing it failed to adequately defend against popular sentiment. Such critiques underscored his belief that judges must interpret the dynamically to counteract democratic excesses, ensuring protections for those lacking political voice. Reinhardt extended this principle to evolving societal rights, advocating an interpretive approach where the adapts to secure personal dignity and for the marginalized. In his 2011 essay "Life to Death: Our and How It Grows," he described the document as a living framework that progressively incorporates safeguards against state-imposed limitations on fundamental liberties, including those related to end-of-life choices and equal treatment in intimate associations. In a 1992 commencement address at School of Law, he implored future lawyers to rebuild institutional confidence among African American youth by vigilantly enforcing . This self-conception aligned Reinhardt with precedents expanding protections for historically oppressed groups, positioning the judge as a defender of constitutional evolution against rigid . He maintained that fidelity to the framers' intent required ongoing vigilance to prevent erosion of , as evidenced in his public commentary on the judiciary's counter-majoritarian role.

Accusations of Judicial Activism and Policy-Making

Critics, including legal scholar Ed Whelan, have accused Stephen Reinhardt of , characterizing his rulings as prioritizing preferred policy outcomes over fidelity to statutory text and precedent. In (2012), a panel including Reinhardt invalidated California's Proposition 8, which had been approved by voters in 2008 to define marriage as between one man and one woman; opponents argued this decision overrode democratic state processes by substituting judicial preferences for voter intent. Similarly, Reinhardt's dissents in death penalty cases, such as his opinion in Thompson v. Calderon (1996), were criticized for halting state executions on grounds seen as extending beyond federal habeas standards, effectively imposing nationwide policy constraints on state sovereignty. Empirical analyses highlight Reinhardt's deviation from textualist restraint. During the Supreme Court's 2010 term, the Ninth Circuit suffered unanimous reversals in 12 cases, with Reinhardt authoring three of those opinions, including rulings on and that expanded federal oversight of state actions. Conservative commentators labeled such patterns as "results-oriented" judging, where outcomes aligned predictably with liberal goals rather than neutral interpretation, as evidenced in empirical rankings of judicial that placed Reinhardt among judges exhibiting legislative-like tendencies. Data on Ninth Circuit panel dynamics further fueled impartiality concerns. Studies of case assignments showed Reinhardt frequently joined panels yielding liberal majorities that state laws, such as in and Second challenges, with outcomes varying markedly by panel composition—liberal-heavy panels under Reinhardt reversed state decisions at rates exceeding 70% in ideologically charged areas, per analyses of en banc processes and panel effects. Critics contended this reflected rather than mere coincidence, as Reinhardt's participation correlated with heightened intervention against state authority, contrasting with more restrained circuits. In one instance, Reinhardt issued an extrajudicial order in 2009 without an active case, prompting accusations of overreach masquerading as adjudication.

Decisions on Civil Liberties and Social Issues

Reinhardt authored the majority opinion in Perry v. Brown (671 F.3d 1052, 9th Cir. 2012), a 2-1 decision invalidating California's Proposition 8, which had amended the state constitution to define marriage as between a man and a woman. The panel held that Proposition 8 violated the by eliminating the right of same-sex couples to marry without serving any legitimate state interest, thereby inflicting a targeted harm on gays and lesbians beyond merely declining to recognize their relationships as marriages. This ruling reinstated following a district court victory, pending further appellate proceedings, and contributed to the circuit's jurisprudence on marriage equality by emphasizing California's prior extension of marital rights to same-sex couples. In Compassion in Dying v. Washington (85 F.3d 1131, 9th Cir. 1996), an decision, Reinhardt wrote for the 8-3 majority striking down Washington's ban on physician-assisted suicide for competent, terminally ill adults. The court ruled that the statute violated the Fourteenth Amendment's by infringing on a fundamental liberty interest in controlling the timing and manner of one's death, analogous to rights recognized in and refusal of treatment cases. The decision immediately lifted the prohibition within the Ninth Circuit's , permitting doctors to assist qualified patients without criminal liability until stayed by the , and spurred national debate on end-of-life by framing the issue as a core aspect of personal dignity rather than mere suicide facilitation. Reinhardt penned the unanimous panel opinion in Richmond Medical Center for Women v. Hicks (No. 05-16324, 9th Cir. 2006), invalidating the federal Partial-Birth Abortion Ban Act of 2003 as applied to the intact procedure commonly used in late-term abortions. The ruling held that the ban imposed an undue burden on women's abortion rights under by lacking an exception for maternal health risks and targeting a safe, prevalent method without medical consensus on . This decision blocked enforcement of the statute in the western states, preserving access to the procedure and reinforcing circuit precedent against post-viability restrictions absent strict health safeguards, until subsequent review. Reinhardt joined the 2-1 panel in Newdow v. United States (328 F.3d 661, 9th Cir. 2003), which declared recitation of the in public schools unconstitutional due to the phrase "under God," adopted by in 1954. The opinion, authored by Alfred Goodwin with Reinhardt concurring, found the reference an impermissible establishment of monotheistic religion in violation of the First Amendment's , as it coerced impressionable children into affirming a religious . The ruling temporarily enjoined the practice across nine western states, prompting widespread school policy changes and heightened scrutiny of in public education until reversal.

Opposition to Death Penalty Applications

Reinhardt frequently authored or joined dissents and opinions granting stays of execution in habeas corpus petitions before the Ninth Circuit, emphasizing procedural irregularities such as and violations of in capital trials. During his tenure from 1980 to 2018, he scrutinized death penalty appeals for errors that warranted relief, often focusing on claims of factual innocence or trial incompetence rather than broad constitutional challenges to the penalty itself. Critics observed an empirical pattern in Ninth Circuit capital cases from the 1980s through the , where Reinhardt consistently voted against upholding sentences, attributing this to a rigorous application of federal habeas standards under 28 U.S.C. § 2254. A prominent example was Thompson v. Calderon (1997-1998), involving Thomas Thompson's conviction for the 1981 rape and murder of Ginger Fleischli in . Reinhardt argued that Thompson's trial was marred by ineffective counsel who failed to investigate and challenge , leading to an unreliable capital verdict; a district court initially vacated the sentence on these grounds before it was reinstated on appeal. In a 1999 lecture, he critiqued the Supreme Court's reversal of the Ninth Circuit's review as prioritizing procedural finality—such as untimely rehearing petitions—over substantive fairness, which he contended allowed execution despite unresolved habeas claims of constitutional error. Thompson was executed on July 14, 1998, prompting Reinhardt's later 2015 assertion that he was "likely innocent" of the capital aspects of the crime, based on evidence of his roommate's greater culpability. Reinhardt's approach extended to defending emergency stays, as in 1992 when he and colleagues issued four last-minute halts in executions to permit habeas review of procedural defects, countering accusations of undue delay by stressing the irreversibility of . He expressed personal reservations about the system's rate, stating he had "yet to see a death penalty case without reversible ," though his opinions grounded relief in specific legal standards rather than outright . This stance drew conservative criticism for allegedly substituting judicial policy for deference to state judgments under the Antiterrorism and Effective Death Penalty Act of 1996, yet Reinhardt maintained it reflected fidelity to evidence of trial flaws.

Supreme Court Reversals and Critique of Restraint

Reinhardt's opinions on the Ninth Circuit were overturned or vacated by the with notable frequency, contributing to the circuit's overall high reversal rate, which exceeded 70% in periods from the onward. Analyses by legal observers have highlighted Reinhardt specifically as holding the record for the most unanimous reversals among federal judges, a metric underscoring deviations from established . This pattern reflected broader critiques of the Ninth Circuit's tendency under Reinhardt's influence to issue rulings that prioritized expansive interpretations of federal protections, often in and regulatory contexts, leading to conflicts with . Prominent examples include (1997), where the unanimously reversed Reinhardt's opinion in Compassion in Dying v. Washington (1996), which had held that Washington's ban on physician-assisted suicide violated ; the Court ruled no such unenumerated right existed under the . In , Reinhardt's 2003 opinion in United States v. Idaho was vacated and remanded by the Supreme Court in Clark v. Martinez (2005), critiquing the Ninth Circuit's expansive reading of detention authority under immigration statutes, which had allowed release of certain non-citizens pending removal. Similarly, in environmental disputes, such as Southwest Center for Biological Diversity v. Bartel (2002), the Supreme Court vacated Reinhardt's ruling granting broad injunctive relief against federal practices, emphasizing limits on judicial intervention in agency . Critics, including conservative legal scholars, have attributed this reversal rate to Reinhardt's minimal adherence to , arguing that his philosophy—favoring intervention to advance perceived progressive outcomes—fostered overreach and engendered national inconsistencies in application. For instance, the Circuit's rulings under Reinhardt often created circuit splits on issues like regulatory stays and enforcement priorities, necessitating Supreme Court correction to maintain uniformity, as the circuit's geographic scope amplified the impact of such decisions on multi-state policies. This dynamic, per these analyses, exemplified how unchecked activism prioritized policy-making over deference to statutes and , exacerbating perceptions of the Circuit's ideological tilt.

Extrajudicial Activities

Involvement with ACLU and Advocacy Groups

Prior to his judicial appointment, Reinhardt served as a member of the Commission on Civil Rights, an independent federal agency established to investigate and report on civil rights issues, including discrimination and enforcement of federal civil rights laws. His role there, beginning in the late under President , reflected his early commitment to advocacy outside of private practice as a trial lawyer in . This affiliation positioned him as a Democratic activist focused on protecting marginalized groups, contributing to his reputation as a defender of progressive causes before ascending to the federal bench in 1980. Reinhardt's closest ties to advocacy organizations stemmed from his 1985 marriage to Ramona Ripston, who led the ACLU of as from 1972 until her retirement in 2011. Ripston's tenure at the ACLU, during which the affiliate pursued high-profile cases on free speech, , and equality, amplified perceptions of Reinhardt's alignment with groups, even as he adhered to judicial ethics prohibiting direct participation. The ACLU of publicly mourned his 2018 death, crediting his personal influence on their shared commitment to countering state overreach, which reinforced his public image as an extension of progressive advocacy networks. These affiliations drew scrutiny over potential conflicts of interest, particularly in cases involving ACLU interests. In the 2010 appeal of Perry v. Schwarzenegger challenging California's Proposition 8 ban on same-sex marriage, ProtectMarriage.com moved for Reinhardt's recusal, citing his wife's leadership at the ACLU of Southern California, which had filed amicus briefs urging invalidation of the proposition. Reinhardt denied the motion, noting the ACLU was not a party and distinguishing it from seven prior instances since 1997 where he had recused himself when the ACLU served as counsel; critics argued the familial tie created an appearance of bias, fueling broader allegations that his external progressive connections undermined judicial impartiality.

Teaching, Writing, and Public Commentary

Reinhardt advanced legal scholarship through numerous articles and essays that championed a approach, emphasizing evolution over textual fixation. In a 1988 Cornell Law Review piece, "Conflict Between Text and Precedent in Constitutional Adjudication," he explored tensions between original textual meaning and evolving precedents, arguing that judges must prioritize practical and historical context rather than rigid literalism, which he viewed as constraining adaptive . Similarly, his contribution to the 1993 anthology The Unpredictable Constitution, edited by Norman Dorsen and others, examined procedural safeguards, the death penalty, and error correction in , critiquing doctrines that prioritized finality over remedial equity. In later writings, Reinhardt sharpened his critique of conservative , particularly Supreme Court trends under Rehnquist and successors. His 2005 UC Davis article, "Life to Death: Our Constitution and How It Grows," delivered as the Edward J. Barrett Jr. Lecture, contended that the document's framers intended progressive adaptation—from slavery's abolition to modern rights expansions—dismissing as a barrier to addressing inequities like disparities. He reiterated this in a 2015 Michigan essay, "The Demise of and the Rise of ," faulting the Court for successive rulings that eroded post-conviction remedies and shielded officials from suits, thereby insulating state errors from federal oversight and favoring institutional expedience over individual redress. Reinhardt supplemented his writings with public speeches and interviews denouncing the Supreme Court's post-1980s conservative pivot. In a 1986 profile, he lambasted the Rehnquist Court's curtailment of Warren-era protections, declaring the judiciary's rightward drift undermined and empowered executive overreach, a stance he maintained despite personal professional risks. By the 2000s and 2010s, amid decisions like and immunity expansions, he publicly assailed the majority for "relentless" constriction of constitutional safeguards, as recounted in accounts of his addresses, positioning himself as a bulwark against what he termed judicial retrenchment. In 2011 remarks covered by the Journal, Reinhardt shrugged off a high reversal rate—over 80% in some tallies—as evidence of ideological clash rather than error, vowing persistence in dissenting against perceived policy-driven conservatism. These extrajudicial expressions, archived at Yale's collections, underscored his advocacy for compassion-driven judging over restraint.

Personal Life and Character

Marriage and Family

Reinhardt married Mary Treman Wainwright in 1956 in , and the couple had three children: Mark, Justin, and Dana. The marriage lasted nearly 25 years before ending in divorce. In 1991, Reinhardt married Ramona Ripston, who had previously served as executive director of the of from 1972 to 2010. The couple resided in , where Ripston continued her advocacy work independently of Reinhardt's judicial role. Reinhardt's children from his first marriage remained in contact with the family, and he was survived by seven grandchildren.

Personal Interests and Public Persona

Reinhardt cultivated a public persona characterized by outspokenness and combativeness, earning descriptions as a for his passionate and unfiltered commentary in judicial opinions, interviews, and public forums. Colleagues and observers noted his eagerness for intellectual and ideological battles, often expressing views with vivid, colorful language that amplified his reputation as an undeniable force on the Ninth Circuit. Outside his professional commitments, Reinhardt's personal interests were limited, with acquaintances reporting he devoted little time to pursuits beyond work, aside from watching sports and frequently attending movies. This focus underscored a life centered on legal and , where he once described his primary "" as efforts to improve government through political involvement prior to his judicial appointment. Born Stephen Roy Shapiro into a Jewish family in on March 27, 1931, Reinhardt adopted the surname from his stepgrandfather, the Austrian-Jewish theater director , who fled Nazi persecution in 1933. Family experiences tied to , including losses among relatives, left a profound mark, prompting Reinhardt to address Jewish issues with unusual candor for a federal judge and shaping perceptions of him as empathetically attuned to persecution and injustice. His interactions with colleagues often reflected ideological divides, as seen in pointed concurrences critiquing conservative peers' reasoning, though personal rapport persisted in some cases amid professional friction.

Death and Aftermath

Final Days and Cremation

Stephen Reinhardt suffered a heart attack and died on March 29, 2018, at age 87 while attending a dermatologist appointment in Los Angeles. He resided in Pasadena, California, at the time. Reinhardt's remains were cremated following his death.

Posthumous Ruling in Yovino v. Rizo

In Rizo v. Yovino, an panel of the Ninth Circuit considered whether prior salary history could constitute a "factor other than sex" under the to justify wage disparities between male and female employees performing equal work. Judge Stephen Reinhardt authored the , concluding that such reliance on prior pay "does not provide an to an Equal Pay Act claim" because it perpetuates rather than remedies past . Reinhardt died on March 29, 2018, after completing the draft but before the decision's formal filing. Despite this, the Ninth Circuit issued the opinion on April 9, 2018—11 days posthumously—listing Reinhardt as author, incorporating a footnote asserting that the opinion and all concurrences/dissents had been "unanimously approved by the participating judges before Judge Reinhardt’s death," and counting his vote toward the 6-5 majority. The posthumous issuance sparked debate over its procedural legitimacy, with critics questioning whether a deceased judge's participation could validly contribute to an decision under Federal Rule of Appellate Procedure 35 and Article III's "life tenure" provision, which limits service to periods of "good Behaviour" rather than extending indefinitely. The Ninth Circuit defended the release by emphasizing Reinhardt's pre-death completion and panel consensus, arguing it honored his full involvement without altering substance. However, appellant Jim Yovino petitioned the , contending the opinion lacked binding force absent a serving judge's vote. On February 25, 2019, the vacated the Ninth Circuit's judgment in an unsigned per curiam opinion, holding that "the Ninth Circuit erred in counting Reinhardt as a member of the en banc majority" because he was no longer a when the decision issued, rendering it non-precedential under Article III constraints. The Court rejected the Ninth Circuit's rationale, stating federal judges "do not serve 'for life'" in perpetuity and that vacating preserved judicial integrity without opining on merits like prior salary's defensibility. This ruling underscored limitations on posthumous judicial acts, prompting discussions on circuit practices for handling unfinished opinions from senior or deceased judges, though it did not mandate recirculation in this instance.

Sexual Harassment Allegations

In February 2020, Olivia Warren, a former law clerk to Judge Stephen Reinhardt, testified before a U.S. House Judiciary subcommittee that Reinhardt subjected her to routine sexual harassment and created a hostile work environment during her clerkship from late May 2017 until his death on March 29, 2018. Warren described near-daily incidents, stating there "may have been a day in which I was not harassed" but she could not recall one, including disparaging comments on her physical appearance—such as calling her "horrifically unattractive"—and vulgar speculations about her marriage, like claiming her husband "must either lack a penis, or not be able to get an erection" in her presence or implying he was a "wimp" or gay. She further alleged Reinhardt instructed her to evaluate female clerkship applicants based on "nicer or longer legs" and overall attractiveness from photos, and on one occasion drew nipples on a sine wave chart while asking if it resembled her breasts. Warren's testimony highlighted a broader pattern of demeaning female staff and rejecting #MeToo-era claims, with Reinhardt reportedly raging that women alleging or "wanted it," should not be believed, and were part of a feminist effort to ruin judges; he also vowed not to hire female clerks amid contemporaneous allegations against other judges like . Over 70 former Reinhardt clerks later signed an supporting Warren's account of she experienced, emphasizing the need for better reporting mechanisms in the . Warren attempted to report the conduct during and after her clerkship, confiding in mentors and contacting her alma mater on August 1, 2018, as well as the federal 's Office of Judicial Integrity anonymously, but received no substantive guidance or investigation due to Reinhardt's . No formal probe occurred, as federal misconduct procedures could not apply posthumously, though the Ninth Circuit chief judge issued a statement taking Warren's testimony "very seriously" and committing to process improvements. The allegations drew attention to contrasts between Reinhardt's public advocacy for civil rights and —earning him acclaim as a "liberal lion"—and the claimed private behavior toward female subordinates.

Legacy

Admiration from Progressive Circles

The (ACLU) eulogized Stephen Reinhardt as the "Chief Justice of the in ," crediting him with treating every appeal against coercive state power as a potential landmark for , including dissents in death penalty cases where he identified reversible errors in all such matters he reviewed. ACLU leaders emphasized his tireless scrutiny of cases involving immigrants, prisoners, and civil rights litigants, portraying him as a defender of the powerless through opinions on equality, reproductive , and the . In its In Memoriam tribute, the featured praises from Justices and , with Kennedy describing Reinhardt as "devoted to protecting the powerless and the oppressed" and dedicated to justice with "warmth and passion for the law," while Sotomayor hailed him as a "giant of our federal judiciary" fiercely loyal to the law and those it affects. Contributors like Ben Wizner of the ACLU lauded his awe-inspiring brilliance and drive in advancing social progress, particularly for the poor, disenfranchised, and underprivileged. Reinhardt garnered acclaim for landmark rulings that aligned with progressive priorities, such as his Ninth Circuit opinion in Hollingsworth v. Perry (2012), which struck down California's Proposition 8 ban on , a decision ultimately upheld by the in 2013. His opinion in the Ninth Circuit case challenging Washington's prohibition on aiding established a constitutional right to physician-assisted death, rooted in personal dignity and autonomy, though later reversed by the . The American Constitution Society's praised these efforts as embodying a judicial favoring individual rights over restrictions. ACLU of executive director Villagra remembered Reinhardt as "brilliant—a great legal mind and writer" who worked seven days a week, exemplified by late-night dissents on death penalty appeals to ensure his objections to perceived injustices were recorded, even when outcomes were unlikely to change. Progressive admirers viewed him as a steadfast to conservative judicial trends, preserving Warren-era values of human dignity amid evolving constitutional interpretations.

Conservative Critiques and Reversal Record

Conservative legal analysts have frequently highlighted Stephen Reinhardt's judicial record as exemplifying liberal activism, with outlets such as asserting that he likely holds the record for the most unanimous reversals by the . This assessment stems from a pattern of opinions overturned in cases spanning civil rights, , and , where critics contend Reinhardt substituted policy preferences for textualist interpretation of statutes and deference to executive or state authority. For instance, in Stanton v. Sims (2015), the issued a unanimous per curiam reversal of a Reinhardt-authored Ninth Circuit ruling that had expanded exceptions beyond established precedent. Posthumous reversals underscored these critiques, as the unanimously overturned Reinhardt opinions in at least three instances after his death on March 30, 2018, including United States v. California (2021), where the Ninth Circuit panel opinion bearing his name was deemed inconsistent with federal immigration enforcement statutes. Such outcomes fueled arguments that Reinhardt's approach contributed to the Ninth Circuit's persistently high reversal rate—often exceeding 70% in reviewed cases during his tenure—reflecting systemic overreach that conservatives viewed as eroding by second-guessing state and local judgments. In 1996-1997 terms, for example, the Ninth Circuit faced reversals in 10 of 12 cases, with Reinhardt involved in eight, prompting claims of ideological bias over legal restraint. Reinhardt's handling of capital cases drew particular conservative ire for allegedly prioritizing moral opposition to the death penalty over affirming valid state convictions, resulting in repeated interventions that delayed executions and were later rejected by higher courts. Critics, including Senator , labeled such rulings "lawless," arguing they imposed personal values—Reinhardt's avowed abolitionist stance—against congressional intent in laws like the Antiterrorism and Effective Death Penalty Act of 1996, which limits federal habeas relief. This pattern, per conservative commentary, exemplified a broader failure to uphold democratic processes, as Reinhardt dissented or authored opinions vacating sentences in high-profile matters like Thompson v. Calderon (1997), only for the to reinstate them, highlighting empirical shortcomings in his legal reasoning.

Influence on Ninth Circuit Jurisprudence

Reinhardt served as a pivotal figure in the Ninth Circuit's liberal bloc during en banc proceedings, where a majority of active judges reviewed panel decisions, often advancing progressive interpretations of federal law in areas such as civil rights, environmental regulation, and criminal procedure. His participation in these high-stakes reviews, which occur when a judge calls for rehearing to address intra-circuit conflicts or perceived errors, helped solidify outcomes favoring expansive readings of statutes like the Clean Air Act and challenges to state initiatives such as California's Proposition 8. This bloc's dominance contributed to the circuit's reputation for rulings that frequently diverged from Supreme Court precedents, evidenced by the Ninth Circuit's reversal rate in SCOTUS cases exceeding 80% in the decade ending around 2010, compared to 71% across other circuits. The jurisprudence Reinhardt helped foster persisted in patterns of high SCOTUS reversals even after his death on March 30, 2018, reflecting entrenched approaches in panel and decisions that prioritized innovations over strict adherence to guidance. For instance, between 2007 and 2021, the Ninth Circuit faced elevated scrutiny, with 10 of 16 California-originated cases reversed in one term alone, underscoring a systemic tilt that his opinions exemplified through lengthy dissents critiquing majority conservatism or perceived abdications of . While direct influence from his dissents on s or SCOTUS remains limited—often rebuked in reversals like those in death penalty stays— they indirectly highlighted tensions, such as in execution delays, prompting broader circuit-wide debates on procedural bounds. Following Reinhardt's departure, the circuit's ideological balance shifted with President Trump's appointments, which by included seven new judges among the 29 active seats, diluting the prior liberal majority and altering dynamics toward more conservative outcomes in and regulatory challenges. This influx, comprising over one-third of active judges by 2020 when compared to prior Democratic appointees, contributed to a moderation in rates, as seen in the 2023-2024 term where only six of 12 reviewed decisions were overturned—a departure from historical highs. Nonetheless, the enduring framework of Reinhardt-era precedents continues to underpin select liberal holdings in rulings, sustaining the circuit's outlier status despite these adjustments.

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