Daniels Sharpsmart, Inc. v. Smith, No. 17-16424 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's grant of a preliminary injunction enjoining California Department of Public Health officials from enforcing the California Medical Waste Management Act (MWMA). The preliminary injunction enjoined Department officials from enforcing the Act on Daniels for the manner in which it disposed of medical waste at facilities outside of the State of California. The panel held that Daniels will likely succeed on the merits of its dormant Commerce Clause claim. Furthermore, the panel held that Department officials were entitled to qualified immunity because Daniels' constitutional rights under the dormant Commerce Clause were not clearly established at the time of the violation. Therefore, the panel reversed the denial of Department officials' motion to dismiss on the basis of qualified immunity.
Court Description: Preliminary Injunction / Qualified Immunity. The panel affirmed the district court’s grant of a preliminary injunction enjoining California Department of Public Health officials from enforcing the California Medical Waste Management Act (“MWMA”) against Daniels Sharpsmart, Inc., and reversed the denial of Department officials’ motion to dismiss on the basis of qualified immunity. The panel held that Daniels will likely succeed on the merits of its claim that the Department officials’ application of the MWMA constituted a per se violation of the dormant DANIELS SHARPSMART V. SMITH 3 Commerce Clause. The panel affirmed the district court’s decision that Daniels was likely to succeed on its claim that California cannot reach out and impose its notions of the proper way to dispose of medical waste upon those who are conducting disposal activities in other states in accordance with the laws of those states. The panel concluded that the district court did not abuse its discretion when it issued the preliminary injunction. The panel held that the doctrine of qualified immunity protected Department officials Richard Pilorin, Alison Dabney, and Ginger Hilton from damages liability where Daniels’ constitutional rights under the dormant Commerce Clause were not clearly established at the time of the violation.
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