Save the Plastic Bag Coalition v. City of Manhattan Beach
This case stemmed from the City of Manhattan Beach's adoption of an ordinance banning the use of "point-of-sale plastic carry-out bags" in the city. Plaintiff, a coalition of plastic bag manufacturers and distributors, claimed standing to maintain a citizen suit to vindicate the public interest in environmental quality. At issue was what were the standing requirements for a corporate entity to challenge a determination on the preparation of an environmental impact report (EIR) and whether the city was required to prepare an EIR on the effects of the ordinance. The court held that plaintiff would qualify for public interest standing here and disapproved Waste Management of Alameda County, Inc. v. County of Alameda's holding that corporations were subject to heightened scrutiny when they filed citizen suits. The court also held that plaintiff, which represented businesses directly affected by the ordinance, had standing in its own right to challenge the city's analysis of environmental impacts. On the merits, the court held that substantial evidence and common sense support the city's determination that its ordinance would have no significant environmental effect. Therefore, a negative declaration was sufficient to comply with the requirements of the California Environmental Quality Act (CEQA), Pub. Resources Code, section 21000 et seq. Accordingly, the judgment was reversed.