National Solid Waste Management Ass'n v. Pine Belt Regional Solid Waste Management Authority

389 F.3d 491, 34 Envtl. L. Rep. (Envtl. Law Inst.) 20132, 59 ERC (BNA) 1376, 2004 U.S. App. LEXIS 22554, 2004 WL 2418336
CourtCourt of Appeals for the Fifth Circuit
DecidedOctober 29, 2004
Docket03-60470
StatusPublished

This text of 389 F.3d 491 (National Solid Waste Management Ass'n v. Pine Belt Regional Solid Waste Management Authority) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Solid Waste Management Ass'n v. Pine Belt Regional Solid Waste Management Authority, 389 F.3d 491, 34 Envtl. L. Rep. (Envtl. Law Inst.) 20132, 59 ERC (BNA) 1376, 2004 U.S. App. LEXIS 22554, 2004 WL 2418336 (5th Cir. 2004).

Opinion

389 F.3d 491

NATIONAL SOLID WASTE MANAGEMENT ASSOCIATION; et al., Plaintiffs,
National Solid Waste Management Association; BFI Waste Systems, BFI Waste Systems of Mississippi LLC; Waste Management of Mississippi Inc., Plaintiffs-Appellees,
v.
PINE BELT REGIONAL SOLID WASTE MANAGEMENT AUTHORITY and Its Board of Commissioners; Covington County; Jones County; Perry County; City of Petal; City of Laurel; City of Hattiesburg, Mississippi; Defendants-Appellants,
Mike Moore, Intervenor-Defendant-Appellant.

No. 03-60470.

United States Court of Appeals, Fifth Circuit.

October 29, 2004.

COPYRIGHT MATERIAL OMITTED John G. Corlew (argued), Virginia Thompson Munford, Watkins & Eager, Jackson, MS, for National Solid Waste Management Ass'n and Waste Management of Mississippi, Inc.

Thomas E. Vaughn, Allen, Vaughn, Cobb & Hood, Gulfport, MS, for BFI Waste Systems.

Moran McLelland Pope, III (argued), Pope & Pope, Hattiesburg, MS, for Defendants-Appellants.

Appeals from the United States District Court for the Southern District of Mississippi.

Before GARWOOD, WIENER and DeMOSS, Circuit Judges.

GARWOOD, Circuit Judge:

The Mississippi cities and counties that belong to the Pine Belt Regional Solid Waste Management Authority (the Authority) enacted solid waste flow control ordinances requiring that all solid waste collected within those cities and counties be disposed of at facilities owned by the Authority. Plaintiffs-appellees, National Solid Wastes Management Association (NSWMA), BFI Waste Systems of Mississippi, LLC (BFI), and Waste Management of Mississippi, Inc. (Waste Management) (collectively, plaintiffs), filed this suit against defendants-appellants, the Authority and its member cities and counties, claiming that the flow control ordinances violated the dormant Commerce Clause. Defendants-appellants now timely appeal the judgment, rendered after a bench trial, declaring the flow control ordinance invalid under the dormant Commerce Clause and enjoining their enforcement. We dismiss plaintiffs' complaint in part for want of standing and with respect to the remainder we reverse and render judgment for defendants-appellants.

Facts and Proceedings Below

In 1989 and 1990, several cities and counties in South Mississippi developed a master plan for the management of the solid waste in the region. The goal of the plan was to develop an environmentally-sensitive and cost-effective program for the disposal of the region's solid waste. Among other things, the master plan recommended the creation of a regional solid waste management authority and the construction of a regional landfill. In 1992, the Authority was formed and the plan was adopted. At that time, the Authority was made up of five counties (Covington, Jones, Perry, Forrest, and Lamar) and three cities (Petal, Laurel, and Hattiesburg) in Mississippi (collectively, the Members). By the time this suit was filed, Forrest and Lamar Counties had withdrawn from the Authority.

In 1992, the Authority issued a request for proposals (RFP) to interested parties, including plaintiffs BFI and Waste Management, regarding the regional landfill. Proposals were to be given for two options: 1) to own, design, permit, build, and operate the landfill for thirty years or 2) to equip and operate the landfill for seven years, with the Authority building and owning the landfill. The RFP included an estimated volume of disposable solid waste that would be generated in the geographic area comprised by the Members1 and a statement that "[u]pon request, the Authority will require each [Member] ... to adopt and enforce a flow control ordinance in order to assure that the entirety of the ... waste stream generated within the [geographic area comprised by the Members] will be managed and disposed of at the [Authority's landfill]." Five proposals were received, including from BFI and Waste Management. Enviro, a company headquartered in Laurel, Mississippi, submitted the lowest bid for Option 2, but did not submit a bid for Option 1. The Authority analyzed the bids, decided to own the landfill, and began implementation discussions with Enviro prior to actual contract negotiations.

In 1996, the Authority issued revenue bonds to finance the construction of the landfill and three transfer stations.2 Also in 1996, Enviro signed a contract with the Authority to operate the Authority's landfill,3 located in Perry County and completed in 1997, and transfer stations. The initial term of the contract was for the life of the first landfill cell or seven years, whichever was less, and was to be automatically extended for one-year terms so long as both parties mutually agreed. In 2000, the Authority refinanced the 1996 bonds and issued additional bonds to finance the construction of a second cell at the landfill.

The Authority generates revenue by collecting fees for the disposal of waste at its landfill and transfer stations. Thus the Authority's generation of revenue is based on the amount of garbage that it receives at its facilities. To the extent that the Authority is unable to generate sufficient income to meet its debt payments, the Members are obligated to make up the shortfall.

From the time the landfill opened, the volume of refuse that passed through and to the Authority's facilities was significantly less than the total amount of potential waste generated in the area comprised by its Members. Although the Authority's issuance of bonds was based on a projected volume of 140,000 tons per year, in fiscal year 1998 the landfill's volume had reached only 105,305 tons and in fiscal year 1999, the volume dropped to 96,032 tons. In 1999, in an attempt to increase its trash collection, and therefore its revenue generation, the Authority extended the service area of the landfill to include a total of 22 counties, which allowed the Authority to receive waste at its landfill from the additional counties which were not Members.4 While the volume of trash deposited at the landfill increased with the expanded service area, it reached a high of only 129,017 tons in fiscal year 2000, with the tonnage decreasing thereafter (to 108,625 in 2001 and to 95,205 in 2002).

Due to an insufficient flow of rubbish through and to its facilities, the Authority realized that, at the current volume of waste, it would not be able to make its July 1, 2004 bond payment. Believing that its facilities needed more garbage to remain viable, the Authority adopted a resolution on July 10, 2002, directing its Members to adopt flow control ordinances requiring that all municipal solid waste generated within the then Member counties (Covington, Jones and Perry) and cities (Petral, Laurel and Hattiesburg) respectively [collectively, the Region] be transported to its landfill or one of its transfer stations.5 Each Member enacted identical ordinances, each applicable only within the geographic area of the particular enacting Member, with September 1, 2002, as the effective date.6

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Hemmingson
157 F.3d 347 (Fifth Circuit, 1998)
Public Citizen, Inc. v. Bomer
274 F.3d 212 (Fifth Circuit, 2001)
Dickerson v. Bailey
336 F.3d 388 (Fifth Circuit, 2003)
Pike v. Bruce Church, Inc.
397 U.S. 137 (Supreme Court, 1970)
Steffel v. Thompson
415 U.S. 452 (Supreme Court, 1974)
Boston Stock Exchange v. State Tax Commission
429 U.S. 318 (Supreme Court, 1977)
Exxon Corp. v. Governor of Maryland
437 U.S. 117 (Supreme Court, 1978)
Hughes v. Oklahoma
441 U.S. 322 (Supreme Court, 1979)
Bender v. Williamsport Area School District
475 U.S. 534 (Supreme Court, 1986)
Bowsher v. Synar
478 U.S. 714 (Supreme Court, 1986)
Dennis v. Higgins
498 U.S. 439 (Supreme Court, 1991)
Wyoming v. Oklahoma
502 U.S. 437 (Supreme Court, 1992)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Bennett v. Spear
520 U.S. 154 (Supreme Court, 1997)
Clinton v. City of New York
524 U.S. 417 (Supreme Court, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
389 F.3d 491, 34 Envtl. L. Rep. (Envtl. Law Inst.) 20132, 59 ERC (BNA) 1376, 2004 U.S. App. LEXIS 22554, 2004 WL 2418336, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-solid-waste-management-assn-v-pine-belt-regional-solid-waste-ca5-2004.