Guidiville Rancheria of California v. United States Of America
- Yvonne Rogers
- 4:12-cv-01326
- U.S. District Court · Northern District of California
- 4
In Guidiville Rancheria v. United States, Judge Rogers partly granted and partly denied a temporary restraining order, reinstating reporting requirements but denying most requested relief.
Upstream Point Molate LLC, Guidiville Band of Pomo Indians, the City of Richmond, the Petitioners in the related appeal, and the parties subject to the amended judgment.
What happened
Guidiville Rancheria of California v. United States of America involved a request by Upstream Point Molate LLC and Guidiville Band of Pomo Indians to restrict the City of Richmond’s actions in an appeal and restore reporting about compliance with an earlier judgment. The plaintiffs argued that the City was repudiating that judgment; the City disputed that implication.
The court found the evidence too ambiguous to resolve the issue at that stage and said the requested restrictions were not based on an actionable claim. It partly granted and partly denied the temporary restraining order: it restored the judgment’s reporting requirement, denied all other relief except for requiring a particular sentence in any proposed City letter to the Ninth Circuit, and canceled the scheduled evidentiary hearing.
Judge Rogers also denied the Petitioners’ request to join the post-judgment matter and respond to the temporary-restraining-order motion, stating that the request was moot and, later, denying it without prejudice. The court said the amended judgment remained valid and enforceable and terminated Docket Nos. 421 and 427.
The detailed version
- Guidiville Rancheria of California v. United States Of America · No. 4:12-cv-01326
- Yvonne Rogers
- Nov. 30, 2021
Background
The court considered a motion for a temporary restraining order filed by plaintiffs Upstream Point Molate LLC and Guidiville Band of Pomo Indians. The underlying action had closed on August 17, 2018, and the court had entered an amended judgment on November 21, 2019.
A related action, identified in the order as the SPRAWLDEF Action, resulted in a judgment against several petitioners, whose appeal was pending in the Ninth Circuit. The petitioners were seeking to invalidate the amended judgment in this case. The plaintiffs alleged that, after a change in the City of Richmond’s city council, the City was repudiating the amended judgment and refusing to defend its legitimacy in the appeal.
Requested relief and analysis
The plaintiffs sought to prevent the City from filing anything in the Ninth Circuit before December 10, 2021, prevent the City from filing anything disavowing the amended judgment, and reorder a joint status report concerning compliance with that judgment. The City argued that its proposed letter did not disavow the amended judgment and did not oppose reordering the status report.
The court explained that, under California law, a settlement agreement is a contract and may be breached through nonperformance, repudiation, or both. Repudiation may be express or implied. The court also noted that the City conceded it would be barred from taking inconsistent positions in the related appeal, but the City argued that taking no action was not an inconsistent action or repudiation.
The court found too much ambiguity in the current record to resolve the issues at that stage. It said the plaintiffs had presented evidence suggesting an intent by the City to repudiate the amended judgment, while the City disputed that implication. The court characterized the City’s changing position about filing a brief supporting the judgment’s legitimacy as, at most, circumstantial evidence of repudiation. The court also noted that the plaintiffs had not filed a motion to enforce the amended judgment.
Rulings
The court granted in part and denied in part the motion for a temporary restraining order. It reinstated the reporting requirement in paragraph 29 of the amended judgment, which had been suspended on December 4, 2020. The first report was due December 13, 2021, with reports due every forty-five days afterward. The first report also had to address the City’s actions concerning the Ninth Circuit appeal.
The court denied all other requested relief, except that if the City filed its proposed letter with the Ninth Circuit, the letter had to state: “The City understands that Appellees The Guidiville Rancheria of California and Upstream Point Molate, LLC will be filing an Answering Brief.” The court said this requirement would reduce potential harm and make clear that the appeal was contested.
The court vacated the December 1, 2021 evidentiary hearing as unnecessary at that point.
The court also denied the Petitioners’ ex parte application and motion to be added as necessary parties to the post-judgment matter and to file a response to the temporary-restraining-order motion, describing that request as moot. The order then stated that the Petitioners’ request was denied without prejudice. It further stated that the amended judgment remained valid and enforceable unless adjudicated otherwise, and that the Petitioners’ concerns appeared properly directed to the appellate proceedings. The order terminated Docket Nos. 421 and 427.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.