71 Cal.App.5th 1010
Cal. Ct. App.2021Background
- In 1971 Oxnard and other cities entered a JPA that made Ventura County the administrator and sole contracting authority for countywide ambulance services; Oxnard lies in EOA6 served by Gold Coast Ambulance.
- The 1980 EMS Act authorized counties to designate local EMS agencies and included a transitional clause (§ 1797.201) allowing cities that provided EMS on June 1, 1980 to continue those services until they ceded them.
- Since 1980 Ventura County established VCEMSA as the local EMS agency and for decades has administered EMS and contracted with providers for the county, including in Oxnard.
- Oxnard grew dissatisfied with provider performance and, in December 2020, notified the County it would withdraw from the JPA effective July 1, 2021 and sought to contract separately for ambulance services; the County approved a contract extension with Gold Coast.
- Oxnard sought a preliminary injunction to bar County and VCEMSA from contracting for ambulance services within the city; the trial court denied the injunction and the Court of Appeal affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Oxnard has authority under the EMS Act to contract for ambulance services after withdrawing from the JPA | Oxnard says it meets §1797.201 grandfathering because it was a JPA signatory that contracted for services on June 1, 1980 and thus can resume contracting | County says Oxnard ceded administration when it joined the 1971 JPA; since 1980 County/VCEMSA administer EMS under the EMS Act and a city may not resume administration it previously ceased | Oxnard lacks authority; §1797.201 only preserves the direct EMS administration a city actually exercised on June 1, 1980 and does not allow resumption after ceding control; injunction properly denied |
| Whether Oxnard would suffer irreparable injury absent an injunction | Oxnard asserts continued poor service and inequitable response times constitute irreparable harm that justifies injunctive relief | County argues Oxnard cannot show likelihood of success on the merits and thus cannot establish irreparable harm for preliminary relief; public integration concerns favor continuity | Court found Oxnard unlikely to prevail on the merits, negating the balance-of-harms requirement for preliminary relief |
| Whether public interest favors granting an injunction | Oxnard argues local control would improve service equity and response times | County contends public interest favors EMS integration under state law and continuity of countywide administration | Court held public interest favored denying the injunction to preserve EMS integration and statewide/local statutory scheme |
Key Cases Cited
- Valley Medical Transport, Inc. v. Apple Valley Fire Protection Dist., 17 Cal.4th 747 (1998) (cities that ceded EMS administration may not later resume it under §1797.201)
- County of San Bernardino v. City of San Bernardino, 15 Cal.4th 909 (1997) (interpreting §1797.201 as narrow grandfathering of only the EMS a city actually administered on June 1, 1980)
- Law School Admission Council, Inc. v. State of California, 222 Cal.App.4th 1265 (2014) (standard for appellate review of preliminary injunction rulings)
- People ex rel. Gallo v. Acuna, 14 Cal.4th 1090 (1997) (distinguishing abuse of discretion review from independent review of pure legal questions)
- Reno v. Baird, 18 Cal.4th 640 (1998) (statutory construction principle to avoid rendering language surplusage)