Labor/Community Strategy Center v. Los Angeles County Metropolitan Transportation Authority

Opinion by Judge SILVERMAN; Dissent by Judge CYNTHIA HOLCOMB HALL.

A district court approved a consent decree that settled a civil rights lawsuit between a group of bus passengers and the Los Angeles County Metropolitan Transportation Authority (“MTA”) concerning the quality of bus service in their community. Fourteen months later, after certain service improvement goals had not been met, the district court-first through a Special Master, then directly-entered detailed orders concerning the operation of the L.A. County transportation system, including an order that MTA immediately acquire 248 additional buses to reduce passenger overcrowding even if that meant diverting funds from other transportation services under MTA’s jurisdiction. MTA appealed. Holding that the Special Master and district court correctly interpreted and applied the Consent Decree, and that the Special Master and district court acted within their power, we affirm the district court.

I. Facts

On August 31, 1994, a plaintiff class of Los Angeles County bus riders filed suit against MTA, alleging that MTA’s transportation policies discriminated against minorities in violation of the Civil Rights Act of 1964…

dissenting:

It is firmly established that, in tailoring a remedy, “federal courts should ‘exercise the least possible power adequate to the end proposed.’ ” Stone v. San Francisco, 968 F.2d 850 , 861 (9th Cir.1992) (quoting Spallone v. United States, 493 U.S. 265, 280 , 110 S.Ct. 625 , 107 L.Ed.2d 644 (1990)). Where the remedy is directed toward a state or local governmental entity, the federal court also must give “appropriate consideration ... to principles of federalism in determining the availability and scope of equitable relief.” Rizzo v. Goode, 423 U.S. 362, 379 , 96 S.Ct. 598 , 46 L.Ed.2d 561 (1976); see also Stone, 968 F.2d at 860-61. Federal courts “should always seek to minimize interference with legitimate state activities in tailoring remedies.” Id. at 860. Because I believe the district court failed to fully account for these limitations on its remedial authority, I respectfully dissent.

I.

The majority concludes that MTA’s consent to the dispute resolution mechanism in the consent decree “relieves many federalism concerns.” Supra at 1050. Some courts have concluded that potential federalism problems posed by a consent decree involving a state governmental entity…