GameStop, Inc. v. Superior Court

CourtCalifornia Court of Appeal
DecidedAugust 22, 2018
DocketE068701
StatusPublished

This text of GameStop, Inc. v. Superior Court (GameStop, Inc. v. Superior Court) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GameStop, Inc. v. Superior Court, (Cal. Ct. App. 2018).

Opinion

Filed 8/22/18

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

GAMESTOP, INC.,

Petitioner, E068701

v. (Super.Ct.No. RIC1706142)

THE SUPERIOR COURT OF OPINION RIVERSIDE COUNTY,

Respondent;

THE PEOPLE,

Real Party in Interest.

ORIGINAL PROCEEDINGS; petition for writ of mandate. John W. Vineyard,

Judge. Petition denied.

Morgan, Lewis & Bockius, Franklin Gowdy, Benjamin Smith and Sharon Smith

for Petitioner.

No appearance for Respondent.

1 Michael A. Hestrin, District Attorney, Elsie J. Farrell and Timothy S. Brown,

Deputy District Attorneys (Riverside), Stephanie A. Bridgett, District Attorney and

Anand B. Jesrani, Deputy District Attorney (Shasta), for Real Party in Interest.

Xavier Becerra, Attorney General, Nicklas A. Akers, Assistant Attorney General,

Michele Van Geldersen, Michael Reynolds, Deputy Attorneys General, and Geoffrey H.

Wright, Associate Deputy Solicitor General, as Amicus Curiae on behalf of Real Party in

Interest.

Mark Zahner and Thomas A. Papageorge, Deputy District Attorney (San Diego),

for California District Attorneys Association as Amicus Curiae on behalf of Real Party in

Following an investigation into violations of the Secondhand Dealers Law (SDL),

the People, by and through the District Attorneys of Riverside and Shasta Counties, filed

an action pursuant to Business and Professions Code section 17200 et seq., (Unfair

Competition Law or UCL) to enjoin petitioner GameStop, Inc., (GameStop) against

noncompliance. GameStop filed a motion to remove the action from the County of

Riverside pursuant to Code of Civil Procedure1 section 394, claiming that the district

attorney, as an official elected by the County of Riverside, was a local governmental

entity. The trial court denied the motion, giving rise to this petition for writ of mandate

by GameStop.

1 All further statutory references are to the Code of Civil Procedures unless otherwise indicated.

2 We issued an order to show cause why the relief prayed for should not be granted.

After considering the arguments in the return, traverse, reply, and the briefs of amici

curiae,2 we deny the petition.

BACKGROUND

We base our opinion on the following operative facts from the return, the traverse,

and the exhibits.3

Following investigations by the Redding Police Department, Shasta District

Attorney’s Office, and law enforcement agencies in Riverside County, the People of the

State of California (real party in interest) filed a law enforcement action under Business

and Professions Code section 17200 et seq., against GameStop, Inc., for violations of the

SDL on April 7, 2017. (Bus. & Prof. Code, §§ 21641, 21628, 21636.) The action was

filed by the District Attorneys of Riverside and Shasta Counties.4

The facts underlying the complaint alleged that GameStop has over 500 stores in

California, and that it uses a buy-sell-trade model, providing customers with an

opportunity to trade in their used consoles, phones, tablets, and other products for store

2The Attorney General of the State of California and the California District Attorneys Association were granted leave to file briefs as friends of the court.

3Petitioner’s requests for judicial notice, filed July 12, 2017, October 18, 2017 and January 5, 2018, are denied. Real party in interest’s requests for judicial notice, filed August 10, 2017, October 2, 2017 and October 26, 2017, are also denied.

4 Although the complaint contains an allegation relating to the authority of the District Attorneys of the Counties of Riverside, Shasta, and Sonoma, the petition and return refer only to the District Attorneys of Riverside and Shasta Counties.

3 credits that can be applied toward merchandise. To prevent theft and “fencing” of stolen

property, and to recover stolen property for the victims of theft, Business and Professions

Code section 21625 et seq., regulates the purchase and resale of preowned “tangible

personal property” by “secondhand dealers.”

The SDL requires secondhand dealers to report the name, address, and photo

identification of the seller, a complete description of the serialized property, a

certification from the seller that she or he is the owner of the property, and a fingerprint

of the seller. (Bus. & Prof. Code, § 21627, subd. (a).) The secondhand dealer must retain

the “tangible personal property” for a period of 30 days (Bus. & Prof. Code, § 21636),

and produce the property to law enforcement, upon request, within one business day

(Bus. & Prof. Code, § 21636, subd. (c)).

During the time period enumerated in the complaint, GameStop failed to comply

with the reporting, holding, and inspection requirements of the SDL. In Shasta County,

police investigated a burglary involving a video game console that was traded or sold to

GameStop in Redding by the thief; the Redding store was not in compliance with the

SDL. In Riverside County, only two out of 16 stores were in compliance with

requirements for obtaining required customer information, submitting that information to

law enforcement, or holding the traded merchandise. In Contra Costa County, eight out

of 12 stores were noncompliant, and in Tulare County, 50 percent of the stores were

noncompliant.

On May 10, 2017, in lieu of an answer, GameStop filed a motion to transfer the

action based on the provisions of sections 394, subdivision (a), and 397, subdivision (b).

4 The trial court denied GameStop’s motion and denied requests for judicial notice made in

support of the motion.

GameStop then petitioned for extraordinary writ relief. After receiving an

informal response from the People, we issued an order to show cause. The parties have

filed a return and a traverse, which we have now considered along with briefing and a

review of the exhibits. We now deny the petition.

DISCUSSION

GameStop contends that the instant action falls within section 394, subdivision (a),

requiring a change of venue when a county or local agency brings a civil suit in its county

against a nonresident corporate defendant. Its argument is grounded on the assertion that

the District Attorneys for the Counties of Riverside and Shasta have an exclusive

financial interest in the outcome of the suit, making the UCL plaintiff in the underlying

action a “local agency.” We disagree. To explain our reasoning, we first examine the

nature of the of the SDL and the UCL, and then the venue provisions of section 394.

1. The Secondhand Dealers and Unfair Competition Laws.

California law provides a statewide mechanism for licensing, regulating, and

overseeing parties who are secondhand dealers. (Bus. & Prof. Code, § 21625.) The UCL

provides an enforcement mechanism respecting the SDL by permitting the Attorney

General, or a district attorney, or a county counsel, to seek preventive relief to enforce a

penalty, forfeiture or penal law in a case of unfair competition. (Bus. & Prof. Code,

§§ 17202, 17204.) The nature of the UCL and SDL statutory schemes are central to the

5 questions of venue for the action, and whether the district attorney is a plaintiff. Thus, a

review of the relevant provisions of the UCL as it pertains to SDL actions is helpful.

Looking at the legislative intent, the SDL was enacted to “curtail the

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