National Shooting Sports Foundation, Inc. v. State of California
This just in. Sorry, no real paragraphs.
Case Digest Summary
The California Supreme Court reversed a court of appeal decision. The court held that, as a matter of law, a court cannot invalidate a statute on the basis of Civil Code §3531's declaration that "[t]he law never requires impossibilities."
Under Penal Code §31910(b)(7)(A), a semiautomatic pistol (SAP) must be micro-stamped with specified information so as to imprint that information in two places on a cartridge case when the SAP is fired. Two trade associations National Shooting Sports Foundation, Inc., and Sporting Arms and Ammunition Manufacturers' Institute, Inc. filed a complaint for declaratory and injunctive relief against the State of California. The associations alleged that it was impossible to effectively comply with §31910(b)(7)(A)'s dual placement microstamping requirements unless the stamping was done on the firing pin. The trial court granted the state's motion for judgment on the pleadings without leave to amend, finding that the action was precluded by the separation of powers doctrine (SOPD). On appeal, the associations argued that the SOPD did not apply because §31910(b)(7)(A) was subject to the statutory proscription in Civ. Code §3531 that "the law never requires impossibilities." The state argued that stamping the information in two places on the firing pin would comply.
The court of appeal reversed and remanded, holding that under §3531, it had to accept the truth of the complaint's properly pleaded facts.
The California Supreme Court reversed, holding that, although in certain circumstances §3531may excuse compliance with a statutory mandate, §3531 cannot serve as a means for entirely invalidating that mandate. The case law recognizes that a statute may contain an implied exception for noncompliance based on impossibility where such an exception reflects a proper understanding of the legislative intent behind the statute. However, the court remarked, it was not aware of any appellate precedent in California that has invoked Civil Code §3531 or impossibility of compliance to invalidate a statute itself. The court distinguished several out-of-state cases cited by the court of appeal to support its expansive reading of §3531. In this case, the Legislature enacted the Unsafe Handgun Act to restrict the manufacture, import, and sale of unsafe handguns. Nothing in either the text or the stated purpose of the Act contemplated that a showing of impossibility could excuse compliance with the statutory requirement, once the statute went into effect. Section 3531's maxim that "[t]he law never requires impossibilities" is an interpretive aid that occasionally authorizes an exception to a statutory mandate in accordance with the Legislature's intent behind the mandate, the court remarked. That maxim has never been recognized as a ground for invalidating a statutory mandate altogether. Justice Chin concurred, with a qualification that courts remain free, based on legislative intent, to construe §31910(b)(7)(A) as inapplicable to a particular case where compliance in that case would be impossible. Liu, J., joined by Cantil-Sakauye, C.J., Chin, Corrigan, Cuéllar, Kruger, Epstein (sitting by assignment; Chin, concurring.
|
06-28-2018, 3:02 PM
Linear Mode
