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Salt River Project v. Solarcity Corp.

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Supreme Court of the United States
Salt River Project v. Solarcity Corp.
Docket number: 17-368
Term: 2017
Court: United States Supreme Court
Important dates
Dismissed: March 22, 2018
Court membership
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch


Salt River Project v. Solarcity Corp. is a case dismissed during the October 2017 term of the U.S. Supreme Court. It was dismissed on March 22, 2018, under Rule 46, which states that both parties may file a request for dismissal at any point during proceedings to have the case dismissed.[1] The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit.

HIGHLIGHTS
  • The case: Generally, parties can only appeal final rulings, and a court's ruling on a motion to dismiss is not considered a final ruling. A federal district court denied Salt River Project's motion to dismiss a lawsuit filed by Solarcity Corp. Salt River Project's motion to dismiss was based on its claim that it was entitled to state action immunity. Salt River Project argued that it was entitled to immediately appeal the district court's denial of its motion to dismiss under the collateral order doctrine, which provides an exception to the general rule prohibiting appeals of non-final rulings. The Ninth Circuit disagreed, concluding that the collateral order doctrine did not apply in cases of state action immunity. Salt River Project appealed to the United States Supreme Court.
  • The issue: "Whether orders denying state-action immunity to public entities are immediately appealable under the collateral-order doctrine."[2]
  • The outcome: The case was dismissed under Rule 46 on March 22, 2018.


    • You can review the lower court's opinion here.[3]

    Background

    Legal question

    This was a case about the scope of the collateral order doctrine. Generally, a party can only appeal the final ruling of a court--it cannot appeal an intermediate ruling that does not resolve an issue in a case. The reason is this: "If non-final decisions were generally appealable, cases could be interrupted and trials postponed indefinitely as enterprising appellants bounced matters between the district and appellate courts."[3] However, there are some exceptions that allow appeals of non-final rulings. An appeal of a non-final ruling is called an interlocutory appeal.[3]

    The collateral order doctrine is one exception that allows an interlocutory appeal. The collateral order doctrine allows interlocutory appeals of rulings on some kinds of state immunity, like sovereign immunity, that prohibit lawsuits against state actors in certain circumstances. For example, imagine a case where a plaintiff has sued a police officer for unlawful arrest. The district court might rule on whether the officer is entitled to immunity from the suit as an initial matter, long before the court rules on whether the facts the plaintiff alleges are true. Under the collateral order doctrine, the parties may be entitled to immediately appeal the district court's ruling as to the officer's immunity, even though that ruling does not resolve the case and does not constitute a final ruling. The issue in this case is whether a ruling on a particular type of immunity--state action immunity--falls within the collateral order doctrine.[3]

    State action immunity protects state governments and state entities from liability under federal antitrust laws. Antitrust laws ban monopolies and prohibit companies from artificially discouraging competition. Under U.S. Supreme Court precedent, state action immunity "protects the States’ coordinate role in government, which counsels against reading the federal antitrust laws to restrict the States’ sovereign capacity to regulate their economies and provide services to their citizens. The doctrine also protects local governmental entities if they act pursuant to a clearly articulated and affirmatively expressed state policy to displace competition."[3]

    Case background

    Solarcity Corp. sells solar energy panels that homeowners use to reduce the amount of electricity they need to purchase from power companies. In Phoenix, Arizona, Salt River Project is the sole provider of traditional electricity. Salt River Project is a political subdivision of the state of Arizona. Salt River Project changed its rates to charge a penalty to customers who obtained some of their power via their own system (like solar panel installation) rather than exclusively through Salt River Project. Solarcity filed suit against Salt River Project, alleging that Salt River Project was in violation of federal antitrust laws "because it had attempted to maintain a monopoly over the supply of electrical power in its territory."[3]

    Salt River Project moved to dismiss Solarcity's suit. Salt River Project argued that it was a state actor entitled to protection from liability under the state action immunity doctrine. The district court denied Salt River Project's motion. Salt River Project argued further that it was entitled to immediately appeal the district court's order under the collateral order doctrine. The district court disagreed, but Salt River Project appealed to the Ninth Circuit.

    Panel opinion

    The United States Court of Appeals for the 9th Circuit concluded that the collateral order doctrine did not apply to allow Salt River Project to appeal the district court's ruling on immunity.

    The court first reviewed the requirements of the collateral order doctrine:

    “ First, an interlocutory order can be appealed only if it is conclusive. Second, the order must address a question that is separate from the merits of the underlying case. Third, the separate question must raise some particular value of a high order and evade effective review if not considered immediately...All three requirements must be satisfied for the ruling to be immediately appealable. The Supreme Court has repeatedly emphasized that these requirements are stringent and that the collateral-order doctrine must remain a narrow exception.[3][4][5] ”


    The court continued, "The collateral-order doctrine allows interlocutory appeals in only a limited category of cases."[6] The court noted that the categories of cases covered by the collateral order doctrine were all cases in which the immunity at issue protected the state entity from being sued in the first place, not just from liability. The court noted, "Unlike immunity from suit, immunity from liability can be protected by a postjudgment appeal." Therefore, the court concluded, the issue was whether state action immunity provided immunity from liability or immunity from suit.[3]

    The court ruled that state action immunity only provides immunity from liability, not immunity from suit altogether. The court wrote, "We and the Supreme Court have described state-action immunity as an immunity from liability." Because state action immunity only provided immunity from liability, the court ruled, Salt River Project was not entitled to appeal the district court's interlocutory order denying its motion to dismiss. In other words, an argument that Salt River Project was not liable in this case could be properly considered after the district court made a final decision on the merits of the case.[3]

    Petitioner's challenge

    The petitioner, Salt River Project, challenged the holding of the United States Court of Appeals for the 9th Circuit. Salt River Project argued that orders denying state-action immunity to public entities are immediately appealable under the collateral order doctrine.

    Certiorari granted

    On September 7, 2017, the petitioner initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 9th Circuit. The U.S. Supreme Court granted petitioner's request for certiorari on December 1, 2017. Argument in the case was held on March 19, 2018.[2]

    Question presented

    Question presented:

    "Whether orders denying state-action immunity to public entities are immediately appealable under the collateral-order doctrine."[2]

    Outcome

    The case was dismissed under Rule 46 on March 22, 2018. To read the stipulation of dismissal, click here.

    See also

    Footnotes

    1. ↑ Supreme Court of the United States, "Stipulation of Dismissal," accessed September 11, 2018
    2. ↑ 2.0 2.1 2.2 Supreme Court of the United States, "Salt River Project v. Solarcity Corp." Question Presented, December 1, 2017
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 United States Court of Appeals for the 9th Circuit, "Salt River Project v. Solarcity Corp." Opinion, June 12, 2017
    4. ↑ Internal citations and quotations omitted.
    5. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Internal quotations omitted.
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