Save the Plastic Bag Coalition v. City of Manhattan Beach
California Supreme Court
52 Cal. 4th 155 (2011)

- Written by Alex Ruskell, JD
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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