The Georgia Electronic Life Safety & System Assoc. v. The City of Sandy Springs, No. 19-10121 (11th Cir. 2020)
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Plaintiffs filed suit challenging a city ordinance and resolution subjecting alarm companies to a series of fines when a false alarm is sounded at one of the properties which they service. The district court dismissed the substantive and procedural due process claims.
The court held that the ordinance and resolution at issue easily survive rational basis scrutiny where imposing a fine on the alarm companies is rationally related to the City's strong interests in reducing the number of false alarms that heavily burden its police and fire departments and waste public resources. The court also held that plaintiffs lack standing to pursue their procedural due process claim as nonjusticiable where there is no cognizable injury for standing purposes when a party fails to attempt an appeal and instead merely points to some procedural elements within a regulation, without alleging how those features injured them or even might potentially cause them some concrete harm.
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