Alameda County Waste Management Authority v. Waste Connections US, Inc.
Annotate this Case
Alameda County Waste Management Authority sought records from three out-of-county landfills (Waste Connections) that disposed of waste originating in Alameda County. The Integrated Waste Management Act, Public Resources Code sections 40000-49260, permits local government entities to inspect and copy specified records kept by landfills concerning waste received at such landfills originating in the government’s geographic jurisdiction “for the purposes of” verifying reports made by the landfills on “disposal tonnages by jurisdiction of origin” and “as necessary to enforce the collection of local fees.” Waste Connections refused to permit the inspections, contending that the Authority had not shown inspection of the records was “necessary” to enforce its fee ordinance. The Authority attached a copy of its fee ordinance and explained that the fee depends on where tonnage originated, the type and amount of waste, and the party responsible for transporting the waste to the landfill, facts that are documented in landfill weight tags of the kind the statute allows government entities to inspect.
The superior court compelled Waste Connections to allow the inspection. The court of appeal affirmed. The “as necessary” language of section 41821.5(g)(2)'s inspection provision requires neither a factual showing nor a factual determination.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.