Attorney General May Bring Action on Behalf of City Against Allegedly Corrupt City Officials; No Claim to City Necessary

In People ex rel. Harris v. Rizzo, published March 20, 2013, the Second District Court of Appeal, Division Three, held that when it appears that a charter city (the City of Bell) is under the control of officials who are allegedly "looting the city's coffers for their own benefit," the state Attorney General may sue the officials on behalf of the city, to remove the city from their control and require them to pay restitution to the city.  The court further held that the Government Claims Act does not require the Attorney General to present a claim to the city before suing the officials; the AG is acting on behalf of the city, and the city need not file a claim with itself before suing its employees for acting outside of their employment.