Villarroel v. Recology
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This case revolves around the filed rate doctrine and its applicability in instances where rates approved by a municipal board are questioned. The plaintiffs, a group of customers, sued Recology, a waste management company, alleging that the company violated the Unfair Competition Law and other laws by bribing a city official to facilitate the approval of Recology’s application for increased refuse collection rates. The trial court ruled in favor of Recology, holding that the claims were barred by the filed rate doctrine. The Court of Appeal of the State of California First Appellate District Division Three reversed the decision, stating that the California version of the filed rate doctrine does not bar this action because the purposes underlying the doctrine – “nondiscrimination” and “nonjusticiability” strands – are not implicated by plaintiffs’ claims. The court also concluded that the judgment in the prior law enforcement action does not pose a res judicata bar to this putative class action. The court remanded the case for the trial court’s consideration of Recology’s remaining challenges in the first instance.
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