Rebecca Flores v. California Public Utilities Commission, et al.

CourtDistrict Court, E.D. California
DecidedApril 2, 2026
Docket1:26-cv-00307
StatusUnknown

This text of Rebecca Flores v. California Public Utilities Commission, et al. (Rebecca Flores v. California Public Utilities Commission, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rebecca Flores v. California Public Utilities Commission, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8 REBECCA FLORES, Case No. 1:26-cv-00307-KES-SKO

9 FINDINGS AND RECOMMENDATIONS Plaintiff, THAT PLAINTIFF’S COMPLAINT AND 10 v. EX PARTE MOTION FOR A TEMPORARY RESTRAINING ORDER 11 BE DISMISSED FOR LACK OF JURISDICTION 12 CALIFORNIA PUBLIC UTILITIES COMMISSION, et al., (Doc. 7) 13 14-DAY DEADLINE 14 Defendants. 15 16 Plaintiff proceeds pro se and in forma pauperis with a civil rights action under 42 U.S.C. 17 section 1983. Plaintiff has filed an ex parte “Application for Temporary Restraining Order and 18 Order to Show Cause Re: Preliminary Injunction,” seeking “an order preventing Defendants from 19 disconnecting her electric service during the pendency of this action.” (Doc. 7). 20 Because the Court lacks jurisdiction, the undersigned recommends dismissing the First 21 Amended Complaint and Application for a Temporary Restraining Order for lack of jurisdiction. 22 I. BACKGROUND 23 Plaintiff is proceeding on her First Amended Complaint (“FAC”) filed on February 9, 24 2026. (Doc. 5). The FAC alleges “ongoing deprivations of Plaintiff’s constitutionally protected 25 property and utility service interests without adequate notice or a meaningful opportunity to be 26 heard.” (Id. at 1). 27 28 1 On March 16, 2026, the undersigned screened the FAC and found it stated a cognizable 2 section 1983 procedural due process claim against Defendants and, therefore, found service of the 3 FAC on Defendants appropriate. (Doc. 6 at 1). 4 II. PLAINTIFF'S TRO MOTION 5 In her application for a Temporary Restraining Order (“TRO”), Plaintiff alleges that she 6 has “previously experienced disconnection of her electrical service” related to what amounts to a 7 billing dispute at the center of the matter before this Court. (See Doc. 7 at 1). Plaintiff alleges 8 that upon receipt of “a final administrative decision from the California Public Utilities 9 Commission dismissing her complaint,” she no longer has “any remaining administrative avenue 10 for relief” and “faces irreparable harm from the loss of essential utility service.” (Id.). In a 11 supplemental declaration, Plaintiff declares that “[o]n or about March 19, 2026 . . . [she] received 12 a disconnection notice from PG&E.” (Doc. 11 at 3). 13 III. LEGAL STANDARD 14 The Court has an obligation to examine subject-matter jurisdiction issues sua sponte. 15 Gonzalez v. Thaler, 565 U.S. 134, 141 (2012). Federal courts are of limited jurisdiction, having 16 subject-matter jurisdiction only over matters authorized by the Constitution and Congress. 17 Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377 (1994). 18 IV. DISCUSSION 19 Under the Johnson Act, federal courts lack jurisdiction over “all suits affecting state- 20 approved utility rates.” Abcarian v. Levine, 972 F.3d 1019, 1029–30 (9th Cir. 2020). The Johnson 21 Act states:

22 The district courts shall not enjoin, suspend or restrain the operation of, or compliance with, any order affecting rates chargeable by a public utility and made by a State administrative 23 agency or a rate-making body of a State political subdivision, where:

24 (1) Jurisdiction is based solely on diversity of citizenship or repugnance of the order to the Federal Constitution; and, 25 (2) The order does not interfere with interstate commerce; and, 26 (3) The order has been made after reasonable notice and hearing; and, 27 (4) A plain, speedy and efficient remedy may be had in the courts of such State. 28 1 28 U.S.C. § 1342. 2 Although the text of the Johnson Act focuses on ratemaking “orders,” the Ninth Circuit 3 has construed it to apply to “all suits affecting state-approved utility rates.” Abcarian, 972 F.3d 4 at 1029–30. Indeed, when “a party challenges the rate-making system, including any particular 5 procedure th[e] . . . system employs, the Johnson Act bars federal jurisdiction.” US West, Inc. v. 6 Nelson, 146 F.3d 718, 722 (9th Cir. 1998). 7 The Ninth Circuit has broadly interpreted the Johnson Act as prohibiting both direct 8 challenges to a specific rate-setting order, as well as indirect challenges that “might have an impact 9 on future rate orders” or that could be used to enjoin enforcement of a past order. Id. at 722–23; 10 Brooks v. Sulphur Springs Valley Elec. Coop., 951 F.2d 1050, 1054 (9th Cir. 1991) (“Congress 11 did not intend to withdraw from federal courts the power to enjoin state rate orders directly but 12 leave undisturbed the power to do so indirectly.”). The Ninth Circuit has cautioned that a 13 Plaintiff’s description or characterization of their challenge is not determinative. US West, 146 14 F.3d at 722. Nor does a plaintiff avoid the Johnson Act by alleging constitutional claims that are 15 unrelated to state ratemaking orders. Id.; Abcarian, 972 F.3d at 1030. 16 The plaintiffs in US West, for example, claimed to challenge a policy rather than a specific 17 rate order. 146 F.3d at 722. The Ninth Circuit was not convinced and instructed that “the way 18 that [plaintiffs] have chosen to describe their grievance does not control whether the Johnson Act 19 bars this action.” Id. And in Abcarian, the Ninth Circuit explained that the Johnson Act would 20 “be a nullity if it could be evaded through the simple artifice of adding some other federal claim 21 to the complaint.” 972 F.3d at 1030. 22 In sum, the Ninth Circuit has repeatedly emphasized the jurisdictional nature of the 23 Johnson Act: 24 In barring federal courts from exercising jurisdiction to interfere with state rate orders in specified circumstances, the text of the Johnson Act necessarily focuses on the 25 jurisdictional basis on which the court is asked to grant such relief. The happenstance that there may or may not be other claims in the case is irrelevant—especially given the fact 26 that ... the additional claims asserted in the action may have nothing to do with state rate orders at all. 27 28 1 Cannara v. Nemeth, 21 F.4th 1169, 1175 (9th Cir. 2021) (quoting Abcarian, 972 F.3d at 1030). 2 And Ninth Circuit precedent establishes that the substance and effect of a plaintiff’s challenge 3 drives the jurisdictional analysis, not the form. US West, 146 F.3d at 722. And the Ninth Circuit 4 has “broadly construed the Act’s jurisdictional bar to oust federal courts of jurisdiction over all 5 challenges affecting rates.” Cannara, 21 F.4th at 1175 (quoting Brooks, 951 F.2d at 1054); US 6 West, Inc. v. Tristani, 182 F.3d 1202, 1207 (10th Cir. 1999) (explaining the Johnson Act is 7 designed to keep rate challenges out of federal courts “lock, stock, and barrel” and relying on US 8 West v. Nelson and other Ninth Circuit cases interpreting the Act). 9 Here, Plaintiff’s claims are subject to the Johnson Act. The First Amended Complaint 10 describes the wildfire surcharge at issue as resulting in “ongoing deprivations of Plaintiff’s 11 constitutionally protected property and utility service interests without adequate notice or a 12 meaningful opportunity to be heard.” (Doc. 5 at 1).

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
U.S. West Inc. v. Tristani
182 F.3d 1202 (Tenth Circuit, 1999)
Mauvais v. Herisse
772 F.3d 6 (First Circuit, 2014)
R. Abcarian v. Meldon Levine
972 F.3d 1019 (Ninth Circuit, 2020)
Alex Cannara v. Karla Nemeth
21 F.4th 1169 (Ninth Circuit, 2021)
US West, Inc. v. Nelson
146 F.3d 718 (Ninth Circuit, 1998)
Desoto Cab Co. v. Picker
196 F. Supp. 3d 1107 (N.D. California, 2016)

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Bluebook (online)
Rebecca Flores v. California Public Utilities Commission, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-flores-v-california-public-utilities-commission-et-al-caed-2026.