Save the Plastic Bag Coalition v. City of Manhattan Beach

52 Cal. 4th 155 (2011)

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Save the Plastic Bag Coalition v. City of Manhattan Beach

California Supreme Court
52 Cal. 4th 155 (2011)

AR

Facts

The City of Manhattan Beach (defendant) passed an ordinance banning the use of point-of-sale plastic bags. The Save the Plastic Bag Coalition (coalition) (plaintiff) sued, arguing that the ordinance was unlawful because the city had failed to prepare an environmental-impact report before passing it. The coalition claimed it was an interested citizen seeking the enforcement of public duties, and the city argued the coalition was a corporation that did not have standing to sue and that the ordinance had little environmental effects. The trial court found that the coalition had standing and that the coalition raised a genuine issue of whether a decrease in plastic-bag use would lead to an increase in paper-bag use, which was actually more harmful to the environment because of the pollution caused by paper-bag production. The city appealed, and the appeals court affirmed. The city then appealed to the California Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Corrigan, J.)

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