San Francisco Taxi Coalition v. City and County of San Francisco, No. 19-16439 (9th Cir. 2020)
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Plaintiffs, taxi drivers and groups representing them, filed suit challenging SFMTA's new rules favoring recent owners of taxi medallions over those who obtained theirs years ago. Plaintiffs alleged that these new rules violate equal protection, substantive due process, the California Environmental Quality Act (CEQA), and state anti-age discrimination law.
The Ninth Circuit affirmed the district court's grant of the government's motion for judgment on the pleadings, ruling that the taxi drivers failed to state plausible claims. The panel held that the rules are rationally related to the legitimate government interests of aiding beleaguered taxi drivers and easing taxi congestion at the airport. The panel also held that the 2018 Regulations are not a project per CEQA, and plaintiffs' pleadings fail to plausibly claim otherwise. Furthermore, plaintiffs' pleadings failed to plausibly allege that California Government Code section 11135 governs the taxi medallion system. Therefore, the panel affirmed the judgment on the CEQA and age discrimination claims, but remanded for the district court to consider granting leave to amend those claims in the event the taxi drivers can allege additional facts to support them.
Court Description: Civil Rights. The panel affirmed the district court’s judgment on the pleadings in favor of defendants, but remanded for the district court to consider whether plaintiffs should be given leave to amend some of their state law claims in an action challenging regulations adopted in 2018 by the San Francisco Municipal Transportation Agency which favored recent owners of taxi permits (called “medallions”) over those who obtained their permits years ago. The 2018 regulations favored taxi drivers who recently obtained medallions from the City of San Francisco for $250,000—only to see ridership dry up in the face of Uber and Lyft and other ride-sharing services. For example, the 2018 regulations gave priority for lucrative airport pick-up rides to recent medallion owners. Several taxi drivers, as well as groups representing them, challenged the 2018 regulations as violating equal protection, substantive due ** The Honorable Roslyn O. Silver, United States District Judge for the District of Arizona, sitting by designation. S.F. TAXI COALITION V. CITY & CTY. OF S.F. 3 process, the California Environmental Quality Act (CEQA), and state anti-age discrimination law. The panel held that rational basis review applied to the equal protection claim because this case did not implicate suspect or quasi-suspect classifications. The panel held that the 2018 regulations were rationally related to the legitimate government interests of aiding beleaguered taxi drivers and easing taxi congestion at the airport. The panel held that the City’s attempt to mitigate the fallout for those most affected by a shift in the taxi market was a permissible state purpose, even if some questioned its policy wisdom. The panel also rejected plaintiffs’ invocation of substantive due process to strike down the 2018 regulations. The panel held that plaintiffs’ pleadings failed to plausibly allege that the 2018 regulations qualified as a project under CEQA. The panel further held that plaintiffs failed to plausibly allege that the 2018 regulations were governed by California Government Code section 11135, forbidding state actions that discriminate based on age. The panel remanded for the district court to consider granting leave to amend those claims in the event the taxi drivers could allege additional facts to support them.
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