National Lifeline Association v. Batjer

Background

National Lifeline Association filed a motion for judgment on the pleadings. The defendants were Marybel Batjer, Liane M. Randolph, Clifford Rechtschaffen, Martha Guzman Aceves, and Genevieve Shiroma, each sued in the official capacity as a commissioner of the California Public Utilities Commission.

The dispute concerned the “Free Rate Rule” in the Commission’s decision establishing support amounts and minimum service standards for California LifeLine. The rule required the Basic Plan and the Standard Plan to be available to California LifeLine participants at no cost.

Court’s analysis

The court held that the Free Rate Rule is preempted by the Communications Act of 1934, specifically 47 U.S.C. § 332(c)(3)(A). “Preempted” means that federal law displaces the conflicting state rule. The court therefore ruled that the Free Rate Rule is null and void against any wireless LifeLine provider.

The defendants argued that Congress’s 1996 amendment to 47 U.S.C. § 254 had partly repealed § 332(c)(3)(A). The court found that argument unpersuasive, stating that § 332(c)(3)(A) and § 254 were not in irreconcilable conflict.

Disposition

Judge Maxine M. Chesney granted National Lifeline Association’s motion for judgment on the pleadings. The court entered judgment for the association and against the defendants.

The court permanently enjoined the defendants, along with their officers, agents, subordinates, and employees, from giving effect to or enforcing the Free Rate Rule against any wireless LifeLine provider. The court also issued all permanent relief and process it considered necessary and appropriate to prevent actions under the rule against wireless LifeLine service providers.