BELLSOUTH TELECOMMUNICATIONS, LLC v. COBB COUNTY

305 Ga. 144
Supreme Court of Georgia·Decided February 18, 2019·No. S17G2011·Published·Cited by 12 cases

Opinion

305 Ga. 144 FINAL COPY

S17G2011. BELLSOUTH TELECOMMUNICATIONS, LLC et al. v. COBB COUNTY et al.

PETERSON, Justice.

Cobb and Gwinnett Counties have sued telephone companies for their

failure to collect and remit to the Counties a charge imposed on subscribers to

offset the cost of 911 services. The telephone companies have raised various

defenses to the Counties’ suits, including that the 911 charge is a tax that the

Counties are not allowed to collect by a lawsuit like this one. The trial court

rejected that argument and allowed the cases to proceed, but the Court of

Appeals vacated that aspect of the trial court’s ruling and remanded because

further development of the record was needed to determine whether the charge

is a tax. We conclude, however, that the charge is a tax regardless of more

factual development, and we conclude that the Counties lack legal authority to

collect that tax in this lawsuit. We reverse.

This case finds its roots in the Georgia Emergency Telephone Number

911 Service Act, OCGA § 46-5-120 et seq. (“the 911 Act”), originally enacted in 1977, see Ga. L. 1977, p. 1040.1 The 911 Act’s purpose was to establish a

statewide 911 system. OCGA § 46-5-121 (a). The statute authorizes local

governments operating a 911 system to impose a monthly 911 charge (“the 911

charge”) on each telephone service that is or would be served by the 911

system.2 OCGA § 46-5-133 (a). The version of the statute in effect when this

litigation was filed capped the charge at $1.50 per month, per telephone service

provided. OCGA § 46-5-134 (a) (1) (A) (2012).3

Telephone companies are intermediaries in the statutory scheme. The

statute provides that “[e]ach service supplier shall, on behalf of the local

government, collect the 9-1-1 charge from those telephone subscribers . . . .”

OCGA § 46-5-134 (a) (1) (B). Telephone companies are entitled to retain an

1 In 2018, shortly after we granted certiorari in this case, a version of the statute containing significant amendments throughout was signed into law, becoming fully effective on January 1, 2019. See Ga. L. 2018, pp. 689, 714, § 4-1. None of those amendments apply to the claims in this case, which largely relate to 911 charges the Counties argue should have been collected prior to the filing of these lawsuits in December 2015 and January 2016. 2 “Telephone service” is defined as “any method by which a 9-1-1 emergency call is delivered to a public safety answering point.” OCGA § 46-5-122 (16.1) (A) (2019); see also OCGA § 46-5-122 (16.1) (2012) (same). 3 The amended version of the statute provides that the monthly charge “shall” be $1.50 absent a reduction designed to avoid excessive accumulation of unexpended revenues. OCGA § 46-5-134 (a) (1) (A) (i), (d) (4) (2019).

2 administrative fee on amounts collected. OCGA § 46-5-134 (d) (1). At the time

this lawsuit was filed, the statute provided that local governments could initiate

a “collection action.” OCGA § 46-5-134 (b) (2012). Although the statute did not

provide expressly against whom that collection action could be brought, in that

same subsection it provided that “[e]very telephone subscriber in the area served

by the emergency 9-1-1 system shall be liable for the 9-1-1 charges and the

wireless enhanced 9-1-1 charges . . . until it has been paid to the service

supplier” and that “[a] service supplier shall have no obligation to take any legal

action to enforce the collection of the 9-1-1 charge or wireless enhanced 9-1-1

charge.” Id. The statute also provided that local governments could audit the

telephone companies with respect to the collection and remittance of the 911

charge. See OCGA § 46-5-134 (d) (4) (2012).4

The Counties sued Bellsouth Telecommunications, LLC and Earthlink,

4 The 2018 amendments created the Georgia Emergency Communications Authority (“the Authority”), comprising all local governments. See Ga. L. 2018, pp. 689, 691, § 1-1 (OCGA § 38-3-182 (a) (2018)). The amendments shifted to the Authority the right to bring collection actions and audit service providers and clarified that collection actions may be initiated against subscribers. Id. at p. 697, § 1-1 (OCGA § 38-3-189 (a) (1) (2019)), p. 707, § 2-12 (OCGA § 46-5-134 (b) (2019)). The Authority also is now authorized to bring an administrative action for a civil penalty against telephone companies that fail to bill the monthly 911 charges. Id. at pp. 694-695, 697-698, § 1-1 (OCGA §§ 38-3-182 (l), 38-3-189 (c) (2019)).

3 Inc., Earthlink, LLC, Deltacom, LLC, and Business Telecomm, LLC

(collectively, “the Telephone Companies”) in two separate complaints. The

complaints as amended allege that the Telephone Companies had underbilled

two classes of customers.5 Together the two complaints claim estimated

damages of more than $38.9 million, allege violations of the 911 Act and

common law theories of recovery (including breach of fiduciary duty, fraud, and

negligence), and seek to enforce the 911 Act’s audit provision.

The Telephone Companies moved to dismiss the Counties’ complaints,

arguing that the Counties do not have a right of action to enforce the 911 Act.

The Telephone Companies also argued that a common law claim was not

available because the 911 Act imposes a tax, and a common law action for

recovery of taxes does not lie where a statute provides remedies for collections

of taxes that do not include an action at law. The trial court denied the motion.

It held that the 911 charge is a fee, not a tax, and that the 911 Act, read in

5 The Counties allege the Telephone Companies did not bill customers that purchased services capable of carrying multiple simultaneous calls over a single physical line for every exchange access line available over that line and did not bill Voice Over Internet Protocol (VoIP) customers for every 10-digit telephone number those customers obtained.

4 conjunction with OCGA §§ 51-1-6

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BELLSOUTH TELECOMMUNICATIONS, LLC v. COBB COUNTY, 305 Ga. 144 (Ga. 2019).

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