378 F. Supp. 3d 857
C.D. Cal.2019Background
- Multiple putative class actions by current/former public-school teachers challenge pre-Janus compulsory agency fees and related statutes; plaintiffs seek injunctive relief and refunds.
- Cases consolidated for purposes of motions: Babb, Wilford, Matthews, Martin, and Few; defendants primarily teachers’ unions and state officials.
- Plaintiffs rely on the Supreme Court’s decision in Janus v. AFSCME (overruling Abood) to argue fee collections were unconstitutional and seek retroactive recovery.
- Defendants assert multiple defenses: mootness of prospective relief, a § 1983 good-faith defense for past fee collection, EERA/PERB preemption, newly enacted Cal. Gov. Code § 1159 immunity, and constitutional validity of Cal. Govt. Code § 3558 and Educ. Code § 45060.
- The Court granted all motions to dismiss in full: prospective relief claims dismissed as moot; § 1983 claims for refunds dismissed with prejudice based on good-faith defense; state-law claims barred by § 1159 and EERA; other statutory and antitrust challenges rejected; limited claims remaining only where plaintiffs consented or mootness not resolved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of prospective injunctive relief against collecting agency fees | Plaintiffs seek injunction to stop future fee collection post-Janus | Unions have ceased collection and promise compliance; therefore claim is moot | Moot — prospective claims dismissed |
| Availability of good‑faith defense to § 1983 refunds for pre‑Janus fees | Plaintiffs say no good‑faith defense (analogy to conversion, strict liability; equitable relief; return of seized property) | Unions relied on Abood and state law; good‑faith defense applies to private entities and to monetary relief | Good‑faith defense applies; § 1983 refund claims dismissed with prejudice |
| Preemption and statutory immunity for state‑law claims (EERA and Cal. Gov. Code § 1159) | Plaintiffs say state tort/restitution claims survive despite EERA and SB 846/§1159 | Defendants argue EERA displaces common‑law claims and §1159 bar retroactive recovery | EERA/§1159 bar the state‑law claims; §1159 is constitutional; state claims dismissed with prejudice |
| Validity of Cal. Gov. Code § 3558 (employee contact disclosure) | Plaintiffs contend compelled disclosure chills associational rights; exacting scrutiny required | Defendants say contact information is content‑neutral, serves union’s duty to represent, opt‑out reduces burden | §3558 constitutional under exacting scrutiny; claim dismissed |
| Validity/standing to challenge Cal. Educ. Code § 45060 (resignations in writing to union) | Martin alleges §45060 prevents effective resignation via employer email and burdens First Amendment | Defendants: Martin’s resignation processed; requirement to notify union in writing is reasonable | Claim dismissed as moot or fails on merits; dismissed with prejudice |
| Antitrust challenge to exclusive representation and collective bargaining terms | Martin argues exclusive representation and pay scales are anticompetitive | Defendants invoke state‑action immunity, labor exemptions, and Noerr‑Pennington | Antitrust claim dismissed with prejudice |
| Challenge to exclusive representation system (Few) | Few contends exclusive representation violates First Amendment | Defendants rely on Knight precedent upholding exclusive representation | Claim foreclosed by Knight and Mentele; dismissed with prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requires more than speculative allegations)
- Wyatt v. Cole, 504 U.S. 158 (discussing availability of good‑faith defenses in §1983 context)
- Richardson v. McKnight, 521 U.S. 399 (qualified immunity and private defendants analysis)
- Clement v. City of Glendale, 518 F.3d 1090 (9th Cir. 2008) (private entity may assert good‑faith defense to §1983)
- Janus v. AFSCME Council 31, 138 S. Ct. 2448 (Supreme Court decision overruling Abood and forbidding compelled agency fees)
- Abood v. Detroit Bd. of Ed., 431 U.S. 209 (prior precedent authorizing agency fees)
- Minnesota State Bd. for Community Colleges v. Knight, 465 U.S. 271 (exclusive representation does not violate nonmember rights)
- NAACP v. Alabama, 357 U.S. 449 (compelled disclosure of membership and associational privacy)
- Landgraf v. USI Film Prods., 511 U.S. 244 (retroactivity principles)
- Ileto v. Glock, Inc., 565 F.3d 1126 (9th Cir. 2009) (legislative retroactive immunities and due process)
- Mentele v. Inslee, 916 F.3d 783 (9th Cir. 2019) (application of exacting scrutiny in organized‑labor compelled‑disclosure context)