Opposition Brief — Johnson County Board of County Commissioners v. Southwestern Bell Wireless, Inc.

No. 99-1575

ee ee

IN THE

Supreme Court of the United States

JOHNSON COUNTY BOARD OF

COUNTY COMMISSIONERS,

Petitioner,

V.

SOUTHWESTERN BELL WIRELESS, INC., fka

SOUTHWESTERN BELL MOBILE SYSTEMS, INC.,

as General Partner of Kansas City SMSA Limited Partnership;

and KANSAS CITY SMSA UNLIMITED PARTNERSHIP,

Respondents.

On PETITION FOR A WRIT OF CERTIORARI TO THE

UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT

RESPONDENTS’ BRIEF IN OPPOSITION

DIANE P. DUVALL

Curtis M. HOLLAND

FRANK A. Caro, JR.*

POLSINELLI, WHITE,

VARDEMAN & SHALTON

Attorneys for Respondents

6201 College Boulevard

Suite 500

Overland Park, Kansas 6621 1

* Counsel of Record (913) 451-8788

159395 @J Counsel Press LLC

(800) 274-3321 + (800) 359-6859

eh Bitiatal

RESPONDENTS’ OBJECTION TO QUESTIONS

PRESENTED IN PETITIONER’S PETITION

The Respondents, according to Rule 15.2, object to

Petitioner's question presented. The sole question presented

1S:

Did the Tenth Circuit correctly conclude that

the Federal Communications Act of 1934, as

amended, impliedly preempts Petitioner’s

attempts to regulate radio frequency interference

(“RFI”) through its “Interference Amendment” to

its local zoning regulations?

CORPORATE DISCLOSURE STATEMENT OF

SOUTHWESTERN BELL WIRELESS, INC., F/K/\

SOUTHWESTERN BELL MOBILE SYSTEMS, INC.,

AS GENERAL PARTNER OF KANSAS CITY SMSA

LIMITED PARTNERSHIP; AND KANSAS CITY SMSA

UNLIMITED PARTNERSHIP

Pursuant to Rule 29(6) of the Rules of the Supreme Court

of the United States, Respondents, by and through their

attorneys, respectfully submit this corporate disclosure

statement:

Southwestern Bell Wireless, Inc. is 80% owned

by Southwestern Bell Mobile Systems, Inc.

(SBMS) and 20° o owned by Pacific Telesis Group

(PTG). SBMS and PTG are wholly owned by SBC

Wireless, Inc., which is wholly owned by SBC

Communications, Inc.

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TABLE OF CONTENTS

Respondents’ Objection To Questions Presented In

Petitioner's Petition ......{........000205-.

Corporate Disclosure Statement Of Southwestern

Bell Wireless, Inc., f/k/a Southwestern Bell

Mobile Systems, Inc., As General Partner Of

Kansas City SMSA Limited Partnership, And

Kansas City SMSA Unlimited Partnership .....

i ce lc ae ena dee wees

Table of Cited Authorities ...............

ES De a ere eae

Reasons For Denying The Writ ..........------

l.

II.

The Court’s Decision Below Was In

Accord With This Court’s Pnor Determinations

Concerning The Comprehensive And Exclusive

Jurisdiction Of The FCC Over “Technical

Matters’, Such As RFI, Associated With The

Transmission Of Broadcast Signals And

Accordingly, Presented No Unresolved

Important Question Of Federal Law. ......

Petitioner's Concerns Over The Tenth

Circuit’s Alleged Lack Of Consideration As

To “Whether The Local Regulation Could

Constitutionally Co-Exist With Federal Law

Regulations,” Presents No Question For This

Court As Field Preemption Exists. ........

Page

Wt

IIT.

IV.

iv

Contents

Petitioner's Concern Over “Whether The

Tenth Amendment Limits The Power Of

Federal Law In Preempting, By Implication,

The Authority Of Local Government” To

Regulate Matters Of Public Safety Does Not

Present A Question For Th: « ourt As This

Court Has Previously H°id Preemption

Principies Apply Even To Matters Of Special

Concern To The States And RFI Regulation

Is Not A Traditional Local Interest, But

Rather A National Interest Preempted By

PS, vk 5 eeu cewsa sd aa as en os

The Court Below Properly Applied The Legal

Principles Established By This Court In

Determining That Federal Law Impliedly

Preempted Petitioner’s Interference

oo ECT eT er ere eer err rey

a i asta et AOI teen Poe

Page

TABLE OF CITED AUTHORITIES

Cases:

Barnett Bank of Marion County, N.A. v. Nelson,

517 U.S. 25, 116 S. Ct. 1103, 134 L. Ed. 2d 237

(1996) 00 cnc ccc crea ceases saceapanassnceeys

Capital Cities Cable, Inc. v. Crisp, 467 U.S. 691,

104 S. Ct. 2694, 81 L. Ed. 2d 580 (1984) ......

Chevron USA, Inc. v. National Resources Defense

Council, Inc., 467 U.S. 837 (1984) ........--.

City of New York v. FCC, 486 U.S. 57, 108 S. Ct.

1637, 100 L. Ed. 2d 48 (1988) ..........-.---.

English v. General Elec. Company, 496 U.S. 72

(1990) oo occ cc ccc aseeO hid wannwes pennant

Federal Communications Commission v. Pottsville

Broadcasting Co., 309 U.S. 134 (1940) .....--

Fidelity Fed. Sav. & Loan Ass'n v. de la Cuesta,

458 U.S. 141 (1982) 2.0... 2c ccc ceesccccseas

Head v. New Mexico Board of Examiners in

Page

6, 10

10

1]

VI

Cited Authorities

Page

Hillsborough County v. Automated Med. Lab., Inc.,

471 U.S. 707, 105 S. Ct. 2371, 85 L. Ed. 2d 714

(19GS) on 00 sSess00nn ese ee eee #, 9,

Hines v. Davidowitz, 312 U.S. 52, 61 S. Ct. 399,

SL. BE. SER CESS occ acne enero e eee 6,7

In the Matter of 960 Radio, Inc., FCC 85-578

(November 4, 19S) «ikea e sesso 9

National Broadcasting Co. v. United States, 319 U.S.

190, 63 S. Ct. 997, 87 L. Ed. 1344 (1943) ....5,7, 11

Rice v. Santa Fe Elevator Corp., 331 U.S. 218,

67 S. Ct. 1146, 91 L. Ed. 1447 (1947) ....... 6,9, 10°

Wisconsin Pub. Intervenor v. Mortier, 501 U.S. 597

CEPT) 4 css besos ewe 8,9, 10

Statutes:

28 U.SA.. 6 2508 +3650 eee sees eee l

47 USL. § MF ica Sip eM e yews aweks 5

47 U.S.A. § SSR: iieixsthek eee l

47 USL. § 134, eS 6 a ee 4

K.S.A. § 1PS0O8 0 iio eeenenaneee eee l

—_s ts oe ee ee dats

Vil

Cited Authorities

Page

United States Constitution:

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INTRODUCTION

Petitioner ambitiously attempts to make a “federalism

case,” out of a relatively straightforward declaratory

judgment action involving well-established principles of

preemption of local government action by federal law. What

is Clear from the Petition, however, is that this case presents

ho “contlict”™ among the lower courts, no important and

unresolved question of constitutional law and no other

important, unresolved question of federal law.

Respondents instituted the underlying action seeking

declaratory and injunctive relief pursuant to 28 U.S.C.

§ 2201, 47 U.S.C. § 332(c)(7) and K.S.A. § 19-2964. In

particular, Respondents sought to establish that Petitioner's

attempts to regulate radio frequency interference (“RFI”)

through its adoption of certain amendments to its zoning

regulations for communication towers and communication

antennae (collectively referred to as the “Interference

Amendment”), and the conditioning of its approval of

Respondents’ application for a conditional use permit on

compliance with said amendment, was illegal and

unreasonable because they violated the Federal

Communications Act of 1934, as amended. Given the fact

this case solely involved a matter of law, i.e., the issue of

preemption of Petitioners’ Interference Amendment to its

zoning regulations, Respondents promptly filed a Motion for

Summary Judgment. The district court below granted

summary judgment in favor of Respondents, invalidating

Petitioner's regulation, as impliedly preempted by federal

law, and rejecting Petitioner's contention that such

preemption violated the Tenth Amendment's reservation of

state powers.

2

On appeal, Petitioner challenged the district court’s

conclusions and further contended that the district court’s

order was over-broad and that issues of fact precluded

summary judgment. The court of appeals below rejected

Petitioner’s contentions and affirmed the district court’s

decision holding that: (i) Petitioner’s attempts to regulate

RFI through its amendments to its zoning regulations were

impliedly preempted by federal law; (ii) this preemption did

not violate the Tenth Amendment; (iii) the district court’s

order was not over-broad; and (iv) the district court did not

otherwise err. (Pet. App. A, 2a).

Petitioner’s Statement of the Case erroneously suggests

that the Interference Amendment at issue is a mere “zoning”

regulation, which focuses only on public safety issues and

does not substantially regulate in a federal area of concern

or impact national uniformity issues. (Pet. 6). As recognized

by the court below, however, Petitioner’s Interference

Amendment “extends beyond traditional zoning authority

(i.e., placement, construction and modification) and into

radio telecommunications, an area of FCC [exclusive]

authority.” (Pet. App. A, 10a-lla). Under Petitioner’s

Interference Amendment, communications towers and

antennae cannot operate in a manner that interferes with

public safety communications. (Pet. 4). The Interference

Amendment grants the county’s zoning administrator

authority to determine when interference exists and, after

notice and opportunity for a hearing, to force the antenna

site to cease operations. (Pet. App. A, 3a-4a). The

Interference Amendment provides, in pertinent part, as

follows:

(2) [The permit holder] shall be responsible,

immediately upon notification by the zoning

3

administrator or the public safety agency, to

investigate the cause of the interference,

disruption, or degradation and to determine a

method .. . to remedy the problem.

(3) [The permit holder] shal/ within 24 hours

after receiving notice of the disruption, remedy

the problem or show to the satisfaction of the

zoning administrator that the tower or other site

equipment is not the cause of the interference or

disruption. If the interference .. . causing the

functional interruption is not remedied within the

24 hours, then the zoning administrator may upon

two days written notice to the [permit holder],

set a hearing to show cause why the applicable

Permit shall not be terminated and the

site ... Shall not cease operation until the

problem is remedied. The hearing shall be

temporarily stayed [for two days], however, if the

[permit holder] seeks immediate technical

assistance and advice .. . from the FCC.

(5) [The permit holder] shall be responsible

for the payment of costs to cure the

interference . . . including the fees of any experts

retained to identify or correct the problem. . . .

(Pet. App. A, 4a-Sa).

4

Because the court below properly applied this Court's

well-established legal standards governing preemption

analysis in its review of Petitioner's Interference

Amendment, it correctly concluded that Petitioner's attempts

at regulating RFI were subject to preemption by the Federal

Communications Act of 1934, as amended. As such, no basis

exists for review and this Court should deny the Petition.

REASONS FOR DENYING THE WRIT

l. THE COURT'S DECISION BELOW WAS IN

ACCORD WITH THIS COURT'S PRIOR

DETERMINATIONS CONCERNING THE COM-

PREHENSIVE AND EXCLUSIVE JURISDICTION

OF THE FCC OVER “TECHNICAL MATTERS”,

SUCH AS RFI, ASSOCIATED WITH THE TRANS-

MISSION OF BROADCAST SIGNALS AND

ACCORDINGLY, PRESENTED NO UNRESOLVED

IMPORTANT QUESTION OF FEDERAL LAW.

Petitioner argues that the issue of implied preemption

by the “comprehensive and exclusive nature of the federal

regulatory scheme developed under the Federal

Communications Act of 1934, 47 U.S.C. § 151, et seq., as

amended,” over its Interference Amendment has not directly

been decided by this Court. While it is true this Court has

not directly decided this issue with respect to Petitioner's

particular “Interference Amendment,” which expressly

prohibits RFI with public safety communications, this Court

has directly recognized the FCC's exclusive jurisdiction over

“technical matters, such as frequency allocation... .”

regarding radio signal transmissions. Head v. New Mexico

Board of Examiners in Optometry, 374 U.S. 424, 430 n.6,

5

83S. Ct. 1759, 10 L. Ed. 2d 983 (1963), citing 47 U.S.C.

§ 301. Moreover, in discussing the breadth of the FCC’s

authority over matters such as RFI, this Court has further

observed that ‘[t]he Communications Act... expresses a

desire on the part of Congress to maintain, through

appropriate administrative control, a grip on the dynamic

aspects of radio transmission,” Federal Communications

Commission vy. Pottsville Broadcasting Co., 309 U.S. 134,

138 (1940), in order to “secure the maximum benefits of

radio to all of the people of the United States.” National

Broadcasting Co. v. United States, 319 U.S. 190, 21 7,63 S.

Ct. 997, 87 L. Ed. 1344 (1943). Because, as recognized by

the courts below, Petitioner’s Interference Amendment

focuses on operational and performance matters regarding

telecommunications towers, i.e., expressly prohibiting and

providing mechanisms for responding to RFI with public

safety communications, it impermissibly extends into the

“technical matters” arena of exclusive FCC authority, which

has been directly recognized by this Court. (Pet. 4: Pet. App.

A, 4a-5a, 10a-1 1a).

il. PETITIONER’S CONCERNS OVER THE TENTH

CIRCUIT’S ALLEGED LACK OF CONSIDERATION

AS TO “WHETHER THE LOCAL REGULATION

COULD CONSTITUTIONALLY CO-EXIST WITH

FEDERAL LAW REGULATIONS,” PRESENTS NO

QUESTION FOR THIS COURT AS FIELD

PREEMPTION EXISTS.

Federal law preempts state or local law in three

Situations:

(1) When Congress, in enacting a federal

Stalute, has expressed a clear intent to preempt

Stale law;

6

(2) When it is clear, despite the absence of

explicit preemptive language, that Congress has

intended, by legislating comprehensively, to

occupy an entire field of regulation and has

thereby left no room for the states to supplement

federal law; or

(3) When compliance with both state and

federal law is impossible or when the state law

“stands as an obstacle to the accomplishment and

execution of the full purposes and objectives of

Congress.”

Capital Cities Cable, Inc. v. Crisp, 467 U.S. 691, 699, 104

S. Ct. 2694, 2700, 81 L. Ed. 2d 580 (1984) (citations omitted)

(emphasis added).

The above three alternative methods of federal law

preemption have commonly been referred to as: (1) express

preemption, (2) field preemption; and (3) conflict

preemption. See, e.g., Barnett Bank of Marion County, N.A.

v. Nelson, 517 U.S. 25, 31, 116 S. Ct. 1103, 1108, 134

L. Ed. 2d 237 (1996). This Court has defined the second of

these alternative methods as follows:

Field preemption may be inferred if a federal

scheme of regulation is so pervasive that Congress

must have intended to leave no room for a state

to supplement it or if an act of Congress touches

a field in which the federal interest is so dominant

the federal system is assumed to prohibit

enforcement of state laws on the same issue.

Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230, 67

S. Ct. 1146, 1152, 91 L. Ed. 1447 (1947); see also Hines v.

7

Davidowitz, 312 U.S. 52, 61 S. Ct. 399, 85 L. Ed. 581 (1941).

As recognized by this Court, the Federal Communications

Act of 1934, as amended, provides comprehensive regulation

in the field of technical radio communications, le: ing no

room for supplementation by state or local authority.

See, e ¢., National Broadcasting Co. v. United States, 319

U.s. at 214 (Communications Act of 1934 created a unified

and comprehensive regulatory system for the [radio

transmission] industry.); Head, 374 U.S. 424, 430 n.6 (noting

FCC’s exclusive jurisdiction over technical matters regarding

radio signal transmission.) Accordingly, the courts below

correctly found field preemption of Petitioner’s Interference

Amendment.!

Given that field preemption of RFI was found to exist,

it Was not necessary to look at the third alternative type of

preemption, /.e. conflict preemption, in order to determine

if, in fact, the Petitioner’s Interference Amendment could

constitutionally co-exist with federal law. See City of New

York v. FCC, 486 U.S. 57, 63, 108 S. Ct. 1637, 100 L. Ed.

2d 48 (1988) (noting that beyond conflict preemption, in

proper circumstances, it may be determined that a federal

agency's authority on a given issue is exclusive and preempts

any state effort to regulate in the forbidden area.) See also

Hillsborough County v, Automated Med. Lab., Inc., 471 U.S.

707, 716, 105 S. Ct. 2371, 2376, 85 L. Ed. 2d 714 (1985)

(noting that even in cases of local regulation of matters

related to health and safety, implicit preemption may exist

where it is the “clear and manifest” intent of Congress or an

agency acting pursuant to congressional delegation to

preempt the field.).

1. The district court below also found conflict preemption to

exist. (Pet. App. B, 32a-34a).

8

Ill. PETITIONER’S CONCERN OVER “WHETHER

THE TENTH AMENDMENT LIMITS THE POWER

OF FEDERAL LAW IN PREEMPTING, BY

IMPLICATION, THE AUTHORITY OF LOCAL

GOVERNMENT” TO REGULATE MATTERS OF

PUBLIC SAFETY DOES NOT PRESENT A

QUESTION FOR THIS COURT AS THIS COURT

HAS PREVIOUSLY HELD PREEMPTION

PRINCIPLES APPLY EVEN TO MATTERS OF

SPECIAL CONCERN TO THE STATES AND RFI

REGULATION IS NOT A TRADITIONAL LOCAL

INTEREST, BUT RATHER A NATIONAL

INTEREST PREEMPTED BY FEDERAL LAW.

Petitioner next argues that this Court should exercise its

discretionary jurisdiction to “consider and rule upon a

fundamental issue of federal constitutional law,” i.e., whether

the Tenth Amendment limits the power of federal law to

preempt local government in its regulation of matters of

special concern, e.g., public safety. This Court has, however,

previously addressed this issue and need not now exercise

its discretionary jurisdiction to revisit that issue.

In Fidelity Fed. Sav. & Loan Ass'n v. de la Cuesta, 458

U.S. 141, 153 (1982), this Court noted that preemption of

law principles apply even to “matter[s] of special concern to

the states” and “the relative importance to the state of its

own law is not material ... for the Framers of our

Constitution provided that federal law must prevail.”

Moreover, as recognized by the courts below, where as here,

it is the “clear and manifest” intent of Congress to preclude

state or local regulation of a given area, e.g., RFI, even a

legitimate exercise of a local government’s police power can

be preempted. See, e.g., Wisconsin Pub. Intervenor v.

9

Mortier, 501 U.S. 597, 605 (1991); Rice v. Santa Fe Elevator

Corp., 331 U.S. 218, 230 (1947). Although Petitioner

repeatedly attempts to characterize its Interference

Amendment, as nothing more than a legitimate exercise of

its police powers, as noted by the court below, Petitioner’s

regulation expressly prohibits RFI with public safety

communications and “RFI regulation is not a traditional local

interest, but a national interest preempted by federal

legislation.” (Pet. App. Al5a-16a). As stated by the FCC:

[F]ederal power in the area of [RF] is exclusive;

to the extent that any state or local government

attempts to regulate in this area, their regulations

are preempted.

See In the Matter of 960 Radio, Inc., FCC 85-578 at {7

(November 4, 1985) available at 1985 WL 193883. The

FCC’s statement, in this instance, is dispositive on the

question of implicit intent to preempt. Hillsborough County

v. Automated Med. Lab., Inc., 471 U.S. at 713, citing Chevron

USA, Inc. v. National Resources Defense Council, Inc., 467

U.S. 837, 843-844 (1984).

Given the FCC’s explicit statement of its intention to

preempt local regulation of RFI, federal preemption of

Petitioner’s Interference Amendment does not violate the

Tenth Amendment and the court’s decision below was in all

respecis proper, leaving review by this Court unnecessary.

10

IV. THE COURT BELOW PROPERLY APPLIED THE

LEGAL PRINCIPLES ESTABLISHED BY THIS

COURT IN DETERMINING THAT FEDERAL

LAW IMPLIEDLY PREEMPTED PETITIONER’S

INTERFERENCE AMENDMENT.

Petitioner contends that not only was the court’s decision

below erroneous, but that the court below failed to consider

and apply the legal standards for preemption analysis

articulated by this Court. This is simply not true.

In a well-reasoned and thorough opinion, the court below

unanimously confirmed the district court’s grant of summary

judgment to Respondent and, in doing so, correctly applied

this Court’s legal standards for the analysis of the preemption

question presented. Specifically, the court below recognized

Congress’ preemption power over state and local ordinances

as articulated by this Court in its holdings in, among other

cases, Wisconsin Pub. Intervenor v. Mortier, 501 U.S. 597,

605 (1991); Barnett Bank of Marion County, N.A. v. Nelson,

517 U.S. 25, 31 (1996); English v. General Elec. Company,

496 U.S. 72, 79 (1990); and Rice v. Santa Fe Elevator Corp.,

331 U.S. 218, 230 (1947). Furthermore, contrary to

Petitioner’s contention that the court below failed to consider

and apply the legal standards set by this Court in

Hillsborough County v. Automated Med. Lab., Inc.,471 US.

707 (1985), the court below expressly addressed and

rejected Petitioner’s reliance on the Hillsborough decision.

(Pet. App. 15a-16a).

Although the [Petitioner] relies on

Hillsborough County v. Automated Med. Lab.,

Inc., 471 U.S. 707 (1985), the case does not

support their argument. The Supreme Court in

11

Hillsborough upheld a county ordinance

regulating health — an area of traditional state

power -— despite federal regulation in the area.

However, the court found no implied preemption

because the federal agency explicitly stated its

intention not to preempt state and local

regulations. See Jd. at 714, 716. Thus,

Hillsborough is inapplicable here because the

FCC has explicitly stated its intention to preempt

local regulations on RFI, see Jn re Mobilecomm,

to F.C.C.R. 5519; In re 960 Radio, FCC 85-578,

1985 WL 193883, and the statutes and legislative

history support Congress’ intent to occupy the

field of RFI issues.

(Pet. App. Al Sa-16a).

Petitioner also seeks this Court’s review of the decision

below in order to have this Court determine whether

Petitioner’s regulation falls within the scope of field

preemption. (Pet. 15). Review of this issue, however, is not

necessary as this Court has previously recognized not only

the exclusive nature of the FCC’s authority in connection

with technical matters, such as RFI, but also the stated

objectives of the Federal Communications Act of 1934 to

provide a “unified and comprehensive regulatory system for

the [radio transmission] industry” and “to maintain control

of the United States over all channels of radio transmission.”

See, e.g., Head, 374 U.S. at 430 n.6; National Broadcasting

Co., 319 U.S. at 214-217. Permitting Petitioner’s attempt at

regulating RFI would seriously impede the FCC’s ability to

Carry Out its statutory mandate of administering a

“unified and comprehensive regulatory system” for the

telecommunications industry. See FCC v. Pottsville Broad.

Co., 309 U.S. 134, 137 (1940). Furthermore, as noted by the

12

court below, “[a] patchwork of varied local regulations across

the country would prevent a functional national

telecommunications network”, and frustrate the objectives

of federal law. (Pet. App. A, 17a). As such, no question as

to the Communications Act’s implied preemption over

Petitioner’s attempts to regulate RFI through its Interference

Amendment exists which merits this Court’s review.

CONCLUSION

Petitioner’s conclusion suggests that “if the opinion

below is allowed to stand, . . . Petitioner will be dependent

upon non-local federal procedures to resolve instances of

interference with public safety operations. ...” (Pet. 17)

(emphasis added). Of course, avoiding multiple and varied

local procedures to resolve instances of RFI, an area within

the FCC’s exclusive jurisdiction, is wholly consistent with

the “clear and manifest” intent of Congress to provide a

“unified and comprehensive regulatory system for the [radio

airwave transmission] industry.” The fact that Petitioner’s

police, fire, and emergency service providers may not be

fully comfortable with the administrative remedies which

are Clearly available to Petitioner in the event of an RFI

incident, simply does not warrant this Court’s review of its

well-established legal standards for analysis of implied

preemption of state and local regulations by federal law.

Both the district court and the circuit court of appeals

below correctly found Petitioner’s Interference Amendment

impliedly preempted by the Federal Communications Act

of 1934, as amended. As such, and for all the foregoing

reasons, no just cause exists for this Court’s review of those

decisions at this time and Petitioner’s Petition should be

denied.

* Counsel of Record

13

Respectfully submitted,

DIANE P. DUVALL

Curtis M. HOLLAND

FRANK A. Caro, JR.*

POLSINELLI, WHITE,

VARDEMAN & SHALTON

Attorneys for Respondents

6201 College Boulevard

Suite 500

Overland Park, Kansas 66211

(913) 451-8788