Justia Government & Administrative Law Opinion Summaries

The plaintiff was an employee who brought claims for wrongful termination, Labor Code violations, and breach of contract against two defendants: the Los Angeles County Metropolitan Transportation Authority (MTA) and the Public Transportation Services Corporation (PTSC). MTA had created PTSC, a nonprofit public benefit corporation, to provide retirement and employment benefits to certain workers and to manage employees who support MTA’s transportation functions. The plaintiff did not file a prelitigation claim under the Government Claims Act (GCA) before suing these entities.The Superior Court of Los Angeles County first granted a motion for judgment on the pleadings in favor of both defendants, finding that the plaintiff had not alleged compliance with the GCA’s claim presentation requirements. The plaintiff was given leave to amend but continued to argue that PTSC was not a public entity subject to the GCA, and that even if it was, the claims presentation requirement should not apply because PTSC had not registered as required by statute. The trial court sustained a demurrer without leave to amend, finding both defendants to be public entities and that PTSC was not required to register separately from MTA. The court entered judgment for both defendants.On appeal to the California Court of Appeal, Second Appellate District, Division One, the plaintiff did not challenge the judgment in favor of MTA but contested the ruling as to PTSC. The appellate court held that PTSC qualifies as a public entity for purposes of the GCA’s claims presentation requirement, given its creation and control by MTA. However, the court found that if PTSC failed to register properly on the Registry of Public Agencies—including with county clerks where it maintains offices—this would excuse the plaintiff’s noncompliance with the GCA. The judgment for MTA was affirmed, but the judgment for PTSC was reversed and remanded to allow the plaintiff to amend his complaint. View "Black v. L.A. County Metropolitan Transp. Authority" on Justia Law

A homeowners association in San Diego, governed by the Davis-Stirling Act and its own bylaws, held a recall election to remove a board director. The association distributed recall ballot materials, including a candidate statement from the sole candidate seeking to replace the director if the recall succeeded. The sitting director sought to include her own statement in these materials to advocate against her removal but was denied by the elections inspector, who reasoned that only candidate statements were included. The association’s election rules defined “association media” to exclude candidate forms or statements attached to ballots.Previously, the Superior Court of San Diego County, in a separate action brought by the same director, found no violation of the statutory equal-access requirement for association media, concluding that all candidates had equal opportunity to submit statements using the association’s forms for regular board elections. Following the recall, the director filed a new petition and complaint challenging the association’s refusal to distribute her statement, alleging violations of Civil Code section 5105, various Corporations Code provisions, and negligence. After a bench trial, the Superior Court again ruled for the association and the inspector, finding the candidate statement was not “association media” under the relevant statute and that the recall vote met statutory requirements.The California Court of Appeal, Fourth Appellate District, Division One, reversed. It held that “association media” as used in Civil Code section 5105 does encompass ballot materials containing candidate statements distributed by the association during an election. The court concluded the director was entitled to equal access to these materials to advocate her position. The court remanded for further proceedings to determine, under Civil Code section 5145, whether the association’s failure to provide equal access affected the election outcome. The judgment was reversed and remanded with directions. View "Arroyo v. Pacific Ridge Neighborhood Homeowners Assn." on Justia Law

A California nonprofit organization focused on preventing deceptive environmental claims filed a lawsuit against a manufacturer of feminine hygiene products. The organization alleged that the manufacturer labeled and advertised certain products, including period underwear, pads, and panty liners, as “organic” or “made with organic cotton” in violation of the California Organic Food and Farming Act (COFFA). The complaint stated that these products contained less than the minimum required percentage of certified organic materials and included nonagricultural and nonorganically produced components not permitted under state or federal organic standards.The case was first heard in the Alameda County Superior Court. The manufacturer moved for judgment on the pleadings, arguing that COFFA applies only to agricultural products, cosmetics, and pet food—not to personal care products such as feminine hygiene items. The Superior Court agreed with the manufacturer and granted judgment on the pleadings, concluding that COFFA did not govern the products in question. The nonprofit timely appealed that decision.The Court of Appeal of the State of California, First Appellate District, Division Two, reviewed the case de novo. The appellate court held that COFFA applies broadly to all products sold as “organic” or containing “organic” materials in California, unless specifically exempted, and that the statute’s plain language encompasses feminine hygiene products. The court found no basis for an implied exception for personal care products and determined that the trial court erred in its interpretation. Therefore, the appellate court reversed the trial court’s judgment, clarifying that COFFA’s standards and labeling requirements apply to the manufacturer’s products at issue. View "Environmental Democracy Project v. Rael" on Justia Law

A city in California owned a downtown parking garage known as Garage 5, which was in poor condition and underutilized according to studies conducted in 2019 and 2022. The city had previously adopted a housing plan to identify public land suitable for housing development. In public meetings and study sessions throughout 2021 and 2022, city staff and consultants presented data showing declining demand for public parking and the high cost of necessary repairs to Garage 5. After further study and public comment, the city’s council passed a resolution in December 2022 declaring Garage 5 to be surplus land under the Surplus Land Act, provided that any future development retain at least 75 public parking spaces.The owner of nearby properties, Airport Business Center, filed a petition for writ of mandate and complaint for declaratory relief in Sonoma County Superior Court. The petitioner argued the city had violated the Surplus Land Act by declaring the garage surplus while there was still an ongoing need for public parking and contended that the city’s findings were not supported by the evidence. The Superior Court denied the petition, finding the city’s actions were not arbitrary or capricious, and that there was substantial evidentiary support for the resolution. A temporary stay was granted pending appeal, but the Court of Appeal denied a request for further stay.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. It held that the Surplus Land Act’s requirement that property be “not necessary for the agency’s use” allows a city to designate property as surplus if it is not indispensable for agency operations, even if the property serves a public purpose like parking. The evidence supported the city’s determination, and the findings in the resolution satisfied statutory requirements. The appellate court affirmed the judgment, awarding costs to the city. View "Airport Business Center v. City of Santa Rosa" on Justia Law

A property owner in Los Angeles obtained a density bonus from the city in 2005, allowing him to build one additional housing unit beyond what zoning would otherwise permit, in exchange for agreeing to rent one of the units to low-income households for at least 30 years. This agreement was formalized and recorded against the property in 2006. The owner had previously taken out a mortgage, and the lender recorded its deed of trust against the property in 2005. After the owner defaulted, the lender foreclosed on the property in 2013. Several years later, new owners purchased the property, allegedly unaware of the recorded agreement requiring the low-income rental restriction.Following a notice from the City demanding compliance with the affordable housing agreement, the new owners filed suit in the Superior Court of Los Angeles County, seeking quiet title and declaratory relief. They argued that the affordable housing agreement, recorded after the original deed of trust, was a junior encumbrance extinguished by the foreclosure. The City countered that the agreement was a condition of a building permit and survived foreclosure. The trial court sustained the City’s demurrer without leave to amend, finding that the agreement was a covenant running with the land and survived foreclosure.On appeal, the California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s judgment. The appellate court held that the affordable housing agreement was equivalent to a “condition attached to a permit” under Government Code section 65009, subdivision (c)(1)(E), and thus survived foreclosure. Permit conditions that have not been timely challenged run with the land and remain enforceable against successor owners, even those who acquire the property through foreclosure. The court concluded that the plaintiffs failed to state a valid claim and were not entitled to amend their complaint. View "Rodriguez v. City of Los Angeles" on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

An agricultural company opposed a unionization effort initiated by the United Farm Workers of America, who sought certification as the exclusive bargaining representative for the company's employees under a new statutory procedure. The union filed a Majority Support Petition with the Agricultural Labor Relations Board, presenting evidence that a majority of employees supported union representation. The company responded by submitting objections and employee declarations alleging misconduct by the union during the signature collection process. The Board's regional director investigated and determined that the union had met the statutory criteria for certification, leading the Board to certify the union as the employees' representative.Following the certification, the company filed additional objections with the Agricultural Labor Relations Board, including constitutional challenges to the underlying statute. The Board dismissed most objections and set others for a hearing, but stated it could not rule on constitutional questions. While administrative proceedings were ongoing, the company filed a petition in the Superior Court of Kern County seeking to enjoin the Board from proceeding and to declare the statute unconstitutional. The Board and the union argued that the court lacked jurisdiction due to statutory limits on judicial review, but the superior court nonetheless issued a preliminary injunction halting the Board's proceedings. Appeals and writ petitions followed, consolidating the matter before the reviewing court.The Court of Appeal of the State of California, Fifth Appellate District, held that the superior court lacked jurisdiction to consider the challenge at this stage. The court reaffirmed that under California law, employers may not directly challenge union certification decisions in court except in extraordinary circumstances, which were not present here. The proper procedure is for employers to wait until an unfair labor practice proceeding or mandatory mediation is completed and a final order is issued before seeking judicial review. The court reversed the preliminary injunction and ordered dismissal of the company’s petition for lack of jurisdiction. View "Wonderful Nurseries v. Agricultural Labor Relations Board" on Justia Law

The dispute centers on the State Water Resources Control Board’s designation of the Tulare Lake groundwater subbasin as a probationary basin under California’s Sustainable Groundwater Management Act (the Act). The Tulare subbasin is categorized as high-priority and critically overdrafted, requiring coordinated local management and submission of a sustainability plan. Local agencies formed a single groundwater sustainability plan, which the Department of Water Resources twice found inadequate, leading the State Board to designate the subbasin as probationary. Following this, the Board imposed monitoring and reporting requirements with associated fees, prompting farmers and landowners, including Kings County Farm Bureau, to challenge the Board’s actions as exceeding its authority and lacking proper notice.Before reaching the California Court of Appeal, the Superior Court of Kings County reviewed the matter. The trial court had issued a preliminary injunction against the State Board, barring it from enforcing requirements and fees related to the probationary designation. The trial court found the plaintiffs likely to succeed on several claims, including improper denial of “good actor” exclusions and failures in notice, and determined the balance of harms weighed in favor of plaintiffs. A nominal bond was set, and the trial court later denied objections to the bond amount.The California Court of Appeal, Fifth Appellate District, reviewed the preliminary injunction. The appellate court held that the trial court abused its discretion by issuing an overly broad injunction affecting the entire Tulare subbasin, where only certain areas had plausible claims. The court clarified that the State Board must exclude any basin portion where a local agency demonstrates compliance with sustainability goals, but this exclusion does not require an independently approved plan for every area. The appellate court reversed the preliminary injunction and remanded the case for further proceedings, instructing the trial court to consider whether a narrower injunction may be appropriate. The petition for writ of supersedeas was denied as moot. View "Kings County Farm Bureau v. State Water Resources Control Bd." on Justia Law

This case concerns the State Water Resources Control Board's intervention in the Tulare Lake groundwater subbasin pursuant to California’s Sustainable Groundwater Management Act (the Act). After local agencies in the subbasin submitted a groundwater sustainability plan that the Department of Water Resources twice determined to be inadequate, the State Board designated the basin as probationary in April 2024. This designation triggered state-imposed monitoring, reporting, and fee obligations on certain groundwater extractors. In response, the Kings County Farm Bureau and others filed a petition for writ of mandate and complaint, asserting that the State Board exceeded its authority and challenging the validity of the designation and associated fees on several grounds.The Superior Court of Kings County addressed both a demurrer filed by the State Board and a request from the Farm Bureau for a preliminary injunction. The trial court dismissed the equal protection claim with leave to amend, but overruled the demurrer as to claims that (1) the State Board used improper “underground regulations” not adopted under the Administrative Procedure Act (APA), (2) the imposed extraction fee constituted an unlawful tax, and (3) general declaratory relief was appropriate. The trial court also granted a preliminary injunction, temporarily halting the State Board’s enforcement activities.The California Court of Appeal, Fifth Appellate District, reviewed the trial court’s order overruling the demurrer. The appellate court held that all actions by the State Board taken under sections 10735.2 and 10735.8 of the Act—including the designation of a probationary basin—are exempt from the APA unless the State Board voluntarily opts to adopt regulations using APA procedures. Therefore, the claim for improper “underground regulations” could not proceed. The court also held that a challenge to the extraction fee as an unlawful tax was barred by the constitutional “pay first” rule, as no exception applied. Lastly, the court determined that declaratory relief was unavailable because the Legislature provided for review of State Board actions exclusively by writ of mandate. The appellate court ordered the trial court to grant the demurrer without leave to amend as to these three claims. View "State Water Resources Control Bd. v. Superior Court" on Justia Law

An 18-year-old driver, Elijah Henry, collided with Melanie Gilliland’s vehicle after running a red light, causing her severe injuries. At the time of the accident, Henry was being followed by Officer Matthew Harvey of the City of Pleasanton Police Department. Officer Harvey had entered a parking lot to investigate possible vehicle break-ins and, upon seeing Henry’s car leave the lot, made a U-turn to follow it. Henry, who had smoked marijuana earlier, accelerated away, fearing police interaction but denying any belief that he was being pursued for arrest. Officer Harvey did not activate his lights or siren and testified that he did not initiate a pursuit under the City’s vehicular pursuit policy.Gilliland sued both Henry and the City for negligence. The City asserted immunity under California Vehicle Code section 17004.7, which protects public entities from liability for damages caused by fleeing suspects if the entity has a compliant vehicular pursuit policy and provides regular training. The Alameda County Superior Court initially denied the City’s motion for summary judgment, finding that neither an actual nor perceived pursuit occurred under the City’s policy definition. However, after a bench trial before a different judge, the court found the City immune, interpreting “pursued” in the statute according to its ordinary meaning rather than the policy’s definition, and concluded Henry believed he was being pursued.The California Court of Appeal, First Appellate District, Division One, reviewed the case and held that the definition of “pursuit” in the public entity’s vehicular pursuit policy governs both actual and perceived pursuits under section 17004.7. The court found the trial court erred by applying the ordinary meaning of “pursued” and reversed the judgment, remanding for further proceedings using the correct legal standard. The main holding is that statutory immunity under section 17004.7 depends on the policy’s definition of pursuit, not the word’s general meaning. View "Gilliland v. City of Pleasanton" on Justia Law