Case Explained: BROWN, ET AL. V. LOS ANGELES DEPARTMENT OF WATER AND POWER, ET AL.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-13

Docket: 2:24-cv-05152-SVW-JPR

The Ninth Circuit affirmed the district court’s dismissal of the appeal brought by Marvin Brown and Maverick Consulting Group, LLC against the Los Angeles Department of Water and Power and Pandora Consulting Associates, LLC. The court held that the district court did not abuse its discretion in dismissing Maverick for failure to comply with a court order requiring the entity to retain counsel within thirty days, citing the established rule that corporations and limited liability companies must appear through an attorney under Ninth Circuit precedent and local rules. Additionally, the court affirmed the dismissal of Brown’s claims on two alternative grounds: first, Brown conceded he lacks standing as a shareholder to redress injuries to the corporation; second, Brown forfeited any challenge regarding the merits of his federal claims under 42 U.S.C. §§ 1981 and 1983 and Section 1 of the Sherman Act by failing to address them in his opening brief. Consequently, the district court properly declined to exercise supplemental jurisdiction over the remaining state law claims after dismissing all federal claims. The practical consequence is that the case remains dismissed with no further proceedings allowed.

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