Black v. Los Angeles County Metropolitan Transportation Authority

Summary

The California Court of Appeal held that the Public Transportation Services Corporation is a public entity subject to the Government Claims Act because of its creation by and relationship with the Los Angeles County Metropolitan Transportation Authority. The court nevertheless concluded that the plaintiff could amend his complaint to allege that the corporation failed to comply fully with statutory registration requirements, which could excuse compliance with the claims presentation requirement. The judgment was affirmed as to the MTA and reversed as to PTSC.

Holdings

1. PTSC is a public entity for purposes of the Government Claims Act's claims presentation requirement.
2. Black was entitled to amend his complaint to allege that PTSC had not fully complied with Government Code section 53051, because such noncompliance could excuse the claims presentation requirement under section 946.4.

Questions Presented

1. Whether PTSC, a nonprofit public benefit corporation created by MTA and operating under MTA's control, is a public entity subject to the Government Claims Act's claims presentation requirement.
2. Whether PTSC's alleged failure to register with the Secretary of State and the county clerks of counties where it maintained offices could excuse Black's failure to present a claim under Government Code section 946.4.
3. Whether Black was entitled to leave to amend to allege PTSC's noncompliance with the public-agency registration requirements.

Disposition

reversed_and_remanded