Potrero Hills Landfill, Inc. v. County of Solano

Potrero Hills Landfill (“Potrero Hills”), a privately owned solid waste and recycling business in Solano County, California (“the County”), and twenty-two related businesses appeal the dismissal on Youn ger abstention grounds of their 42 U.S.C. § 1983 action for declaratory and injunctive relief challenging the constitutionality of a voter-enacted county ordinance restricting the import of out-of-county solid waste into Solano County — an ordinance that the County itself believes to be unconstitutional and refuses to enforce. We hold that Younger abstention does not apply here. Although private mandamus actions seeking to compel the County to enforce the challenged ordinance were ongoing in state court at the time this case was filed, those state proceedings were brought by private interest groups and therefore did not implicate the state’s unique interest in protecting its vital executive function of law enforcement; nor did they implicate the state’s unique interests in protecting its vital judicial or legislative functions. Put differently, a federal court’s exercise of jurisdiction over Potrero Hills’ claim would not interfere with the state’s exercise of a basic…