## Facts

- The Orange County District Attorney filed an enforcement action under California’s Unfair Competition Law (UCL), Bus. & Prof. Code § 17200 et seq., against multiple pharmaceutical companies, including Abbott Laboratories.
- The complaint alleged the companies intentionally delayed the sale of a generic drug to keep prices high and increase profits from the brand-name version, harming consumers throughout California.
- The District Attorney sought statewide remedies, including injunctive relief, restitution, and civil penalties on behalf of California consumers, not just Orange County residents.
- The pharmaceutical companies moved to strike the complaint’s references to “California” and statewide harm, arguing a county district attorney may enforce the UCL only for conduct within the county’s geographic borders.
- The Orange County Superior Court denied the motion to strike, allowing the statewide allegations and requests for relief to remain.
- In writ proceedings, the Court of Appeal reversed and directed the trial court to grant the motion to strike, reasoning the District Attorney’s authority was limited to Orange County.
- The District Attorney sought review in the California Supreme Court.

## Issues

1. Whether a county district attorney bringing a UCL enforcement action may seek statewide relief (including restitution and civil penalties) for alleged UCL violations occurring outside the district attorney’s county.
2. Whether the UCL’s enforcement scheme or the Attorney General’s supervisory authority requires limiting a district attorney’s UCL action to the county’s territorial boundaries absent the Attorney General’s consent.

## Decision

- The California Supreme Court reversed the Court of Appeal.
- The Court held the UCL does not restrict a district attorney’s authority to the district attorney’s county boundaries and does not bar a district attorney from alleging and pursuing relief for violations occurring outside the county.
- The Court concluded the trial court correctly denied the motion to strike the complaint’s statewide allegations and requests for statewide relief.
- The Court’s ruling reinstated the trial court’s order and allowed the District Attorney to proceed on a statewide basis.

## Legal Principles

- The UCL grants enforcement authority to multiple public prosecutors (including the Attorney General and district attorneys) and authorizes broad remedies such as injunctions, restitution, and civil penalties.
- Absent an express territorial restriction in the UCL’s text, courts will not read a county-by-county geographic limit into a district attorney’s statutory authority to prosecute unfair competition on behalf of the People of the State of California.
- The Legislature structured UCL enforcement with concurrent authority among different public offices; that structure allows more than one public prosecutor to sue over conduct affecting consumers across the state.
- The Attorney General’s general supervisory authority over district attorneys does not, by itself, narrow the enforcement power the Legislature gave district attorneys under the UCL or require advance approval for statewide UCL claims.
- Limiting district attorneys to county-only relief would conflict with the statute’s remedial design in cases alleging practices that affect consumers across county lines.

## Conclusion

Abbott Laboratories v. Superior Court holds that an Orange County district attorney may bring a UCL enforcement action seeking statewide injunctive relief, restitution, and civil penalties for alleged unfair business practices affecting consumers throughout California, and the UCL does not confine the district attorney’s authority to Orange County’s borders or require prior authorization from the Attorney General.


Abbott Laboratories v. Superior Court, 9 Cal. 5th 642, 467 P.3d 184, 264 Cal. Rptr. 3d 788 (2020)