Sandra Segal Ikuta

Sandra Segal Ikuta was a United States circuit judge who served on the United States Court of Appeals for the Ninth Circuit from 2006 until her death in 2025. Appointed by President George W. Bush, a Republican, she served nearly two decades on the nation's largest federal appellate court, becoming known as a frequent participant in en banc proceedings and one of the court's most active voices in dissent. Her judicial career followed an unusual professional path that included years as a writer and editor before she attended law school, as well as prestigious clerkships at both the circuit and Supreme Court levels.

Early life and legal career

Born on June 24, 1954, Ikuta was raised in Los Angeles, California. Her educational journey began at Stanford University, where she spent two years before transferring to the University of California, Berkeley, from which she received her Bachelor of Arts degree in 1976. Rather than immediately pursuing law, she continued her studies in journalism, earning a Master of Science degree from Columbia University in 1978.

Following her graduate work in journalism, Ikuta spent seven years working as a writer and editor in various professional capacities. Between 1978 and 1985, she contributed her skills to a diverse array of publications and organizations, including Guilford Press, City National Bank, Unique Publications, and Disney Channel Magazine. This period of her career provided her with experience in communications and editorial work across both private sector and media contexts.

After nearly a decade in journalism and publishing, Ikuta made the decision to pursue a legal career. She enrolled at the UCLA School of Law, where she distinguished herself academically by serving as an editor of the UCLA Law Review. She graduated in 1988 with a Juris Doctor degree and received Order of the Coif honors, a distinction recognizing exceptional academic achievement in law school.

Her entry into the legal profession was marked by highly competitive clerkships. Immediately following graduation, she clerked for Judge Alex Kozinski of the United States Court of Appeals for the Ninth Circuit from 1988 to 1989. This was followed by a clerkship with Justice Sandra Day O'Connor of the United States Supreme Court from 1989 to 1990, one of the most prestigious positions available to a young attorney.

After completing her clerkships, Ikuta joined the prominent law firm O'Melveny & Myers as an associate in 1990. She practiced there for several years and advanced to partner in 1997, spending approximately fourteen years with the firm. Her private practice career was followed by a transition to public service. In January 2004, she became general counsel of the California Resources Agency, where her work focused on protecting natural resources, preserving open space, and maintaining agricultural land. She also served as an alternate director of the Pacific Forest and Watershed Lands Stewardship Council. Ikuta was an active member of The Federalist Society, a conservative and libertarian legal organization, and was known to attend their national events.

Federal appellate service

President George W. Bush nominated Ikuta to the United States Court of Appeals for the Ninth Circuit on February 8, 2006. The nomination was to fill a seat that had been vacant since 2000, when Judge James R. Browning assumed senior status. The vacancy had been the subject of prior controversy; Carolyn Kuhl had previously been nominated to the same position but withdrew her nomination in December 2004 after facing a filibuster by Senate Democrats for approximately one year.

During the confirmation process, Ikuta received support from her former supervisor, Judge Alex Kozinski, who testified on her behalf at the Senate Judiciary Committee hearing. The committee voted unanimously to advance her nomination on May 26, 2006. The full United States Senate confirmed her by a vote of 81 to 0 on June 19, 2006, reflecting broad bipartisan support. She received her commission on June 23, 2006, and began her service on the Ninth Circuit, where she would work alongside Judge Kozinski, for whom she had clerked nearly two decades earlier.

Ikuta's first published opinion as a Ninth Circuit judge was issued on December 27, 2006, in United States v. Baldrich. Over the course of her tenure, she became particularly active in en banc proceedings, in which all active judges of the circuit consider cases of exceptional importance. Between December 2014 and August 2020, she sat on 26 en banc panels, during which time she was the en banc court's most frequent dissenter. Statistical analysis of her voting patterns during this period showed that the judges most likely to agree with her were Judges Consuelo Callahan and Carlos Bea, while the judges most likely to disagree with her were Judges Sidney Thomas, M. Margaret McKeown, and William Fletcher.

In March 2025, it was announced that Ikuta intended to take senior status upon the confirmation of a successor, a form of semi-retirement that would have allowed her to continue hearing cases with a reduced workload. However, her judicial service terminated upon her death on December 7, 2025, at the age of 71. She had been battling pancreatic cancer for approximately three years.

Jurisprudence and legacy

Ikuta's judicial work encompassed a wide range of legal issues that came before the Ninth Circuit. Her opinions addressed matters of criminal procedure, constitutional law, administrative law, and federal-state relations. In several notable instances, her reasoning in dissent or in majority opinions was later adopted or affirmed by the Supreme Court of the United States.

One significant early example involved her dissenting opinion in Dukes v. Wal-Mart, a major employment discrimination class action case. Her dissent articulated reasoning that was largely adopted by the Supreme Court when it later reviewed the case, demonstrating the persuasive quality of her legal analysis even when she was initially in the minority on her own court.

In May 2017, Ikuta dissented when a narrowly divided en banc Ninth Circuit ruled that a policy of the United States District Court for the Southern District of California violated the Constitution's Due Process Clause. The policy in question involved the indiscriminate shackling of criminal defendants during all pretrial hearings. In March 2018, the Supreme Court unanimously vacated the circuit's judgment, vindicating the position Ikuta had taken in dissent.

On July 12, 2019, Ikuta authored the majority opinion in City of Los Angeles v. Barr, a case involving so-called sanctuary city policies. The Ninth Circuit overturned a nationwide injunction that had been issued in 2018, thereby upholding the federal government's authority to give preferential treatment in awarding community policing grants to cities that cooperated with immigration authorities. In her opinion, Ikuta wrote that cooperation relating to enforcement of federal immigration law served the general welfare and met the standard of being germane to the federal interest in providing funding to address crime and disorder problems and enhance public safety, which was among the main purposes of the grant program. The decision was not unanimous, with Judge Kim Wardlaw dissenting.

On February 24, 2020, Ikuta wrote the majority opinion in State of California v. Alex Azar, in which the en banc Ninth Circuit sided with the government by a vote of 7 to 4. The case concerned a Trump Administration rule that withheld Title X funding from health-care providers that performed, promoted, or supported abortion with patients. The majority opinion acknowledged awareness that the rule's main purpose was to stop abortions but concluded that it nevertheless remained constitutional. The opinion relied on the Supreme Court's precedent in Rust v. Sullivan, which had upheld a nearly identical rule during the presidency of Ronald Reagan. Ikuta was joined by Senior Judge Edward Leavy and Judges Jay Bybee, Consuelo Callahan, Milan Smith, Eric Miller, and Kenneth K. Lee, who had been appointed by Presidents Reagan, George W. Bush, and Trump.

On December 4, 2021, Ikuta dissented when a two-to-one majority of a Ninth Circuit panel declined to block the San Diego Unified School District's requirement that students be vaccinated by December 20, reflecting her approach to questions involving government mandates and individual rights.

Throughout her judicial career, Ikuta's work reflected engagement with complex questions of federal law, administrative authority, and constitutional interpretation. Her nearly two-decade tenure on the nation's largest circuit court left a substantial body of opinions addressing the legal issues facing the western United States and beyond.