Friday, August 3, 2018

Don't Shoot at the King When You Need to Hit His Bureaucracy

Templo v. State of California, No. A151094 (D1d3 Jun 18, 2018)

Plaintiffs contend that Code of Civil Procedure § 631—which requires the posting of nonrefundable fees to preserve the right to jury trial—is unconstitutional because it’s a tax that wasn’t approved by a legislative supermajority. So they sued the state for declaratory relief. The trial court granted a motion for judgment on the pleadings, finding that the state wasn’t the proper defendant in such an action. 

In California, the general rule is in a case challenging the constitutionality of a statute is that you don’t sue the state, the governor, or the legislature. Instead, the proper defendant is the public officer or agency tasked with administering the statute. The idea is that that is who has the most significant institutional interest in the final outcome of the litigation. In a case challenging court funding, that agency would be the Judicial Council, which oversees the budget for the state judiciary. 

Problem is, plaintiffs already sued the Judicial Council, but (for reasons unexplained) dismissed it with prejudice at some point earlier in the case. So their story ends here.

Affirmed.

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