Mealey's (September 9, 2019, 2:05 PM EDT) -- PASADENA, Calif. — The Ninth Circuit U.S. Court of Appeals’ ruling in David v. United States regarding conspiracy claims under 42 U.S. Code Section 1985(2) was partially abrogated by the U.S. Supreme Court’s ruling in Haddle v. Garrison, a Ninth Circuit panel ruled Sept. 5, holding that a U.S. Department of Veterans Affairs’ (VA) employee who alleges conspiracy to deter him from testifying in a co-worker’s and his own bias cases doesn’t need to show that the co-worker was unable to present an effective case (Christian Head, M.D. v. Robert Wilkie, et al., No. 17-55942, 9th Cir., 2019 U.S. App. LEXIS 26849)....