HomeMy WebLinkAboutCC 2025-08-26_09c Settlement Agreements with Dist of OpioidsItem 9.c.
MEMORANDUM
TO: City Council
FROM: Matthew Downing, City Manager
BY: Nicole Valentine, Director of Administrative Services
SUBJECT: Opting into Settlement Agreements with Distributors of Opioids;
Purdue Pharma, L.P. National Opioid Settlement
DATE: August 26, 2025
RECOMMENDATION:
1) Adopt a Resolution authorizing the City Manager to enter into the National Opioid
Settlement Agreement with Opioid Distributers, Purdue Pharma, L.P., and the Sackler
Family; and
2) Find that adopting the Resolution opting-into the settlement agreements is not a project
subject to the California Environmental Quality Act (“CEQA”) because the adoption in
itself has no potential to result in either a direct, or reasonably foreseeable indirect,
physical change in the environment. (State CEQA Guidelines, §§ 15060, subd. (b)(2)-(3),
15378.)
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
California is to receive approximately $440 million from the settlements and is required to
distribute these funds pursuant to intrastate allocation agreements for the new
settlements. The City has been allocated 0.024% of the approximate $440 million. The
City can opt into this settlement and potentially receive up to $73,920 in direct funding.
This amount will be disbursed over a period of 15 years, with payments decreasing as
each settlement finishes paying out. The first payments are scheduled to occur in the
latter half of 2025.
BACKGROUND:
The national opioid crisis created by opioid manufacturers, distributors, and dispensers
has been well-documented over the last decade as communities have struggled to
address its devastating impacts. Since 2018, numerous jurisdictions across the country
have been engaged in a multi-jurisdictional lawsuit against some of the principal parties
responsible for creating the crisis. After years of Court-supervised negotiations, the
parties reached a resolution of the case against several defendants.
Page 37 of 98
Item 9.c.
City Council
Opting into Settlement Agreements with Distributors of Opioids; Purdue Pharma,
L.P. National Opioid Settlement
August 26, 2025
Page 2
Litigation brought by states and cities across the United States against the three largest
pharmaceutical distributors of opioid painkillers, Amerisource Bergen, Cardinal Health,
and McKesson (the “Distributors”), and the opioid painkiller manufacturer, Janssen
(owned by Johnson & Johnson) (“J&J”), resulted in two proposed settlements totaling
approximately $26 billion dollars. The City has previously opted into the Distributors and
the J&J Settlements on December 14, 20211, and has started receiving payments.
Between November and December 2022, five additional parties , including Walgreens,
Walmart, CVS, Teva, and Allergan, entered into National Opioid Settlements with terms
identical to the Distributors/J&J Settlements. The City opted into the settlements with
these parties on April 11, 20232. In 2024, Kroger Co. reached a tentative settlement
regarding its outstanding opioid distribution claims and the City opted into this settlement
on July 23, 20243, as well.
In March 2024, the State of California entered into a Subdivision Agreement Regarding
Distribution and Use of Settle Funds with Purdue National Opioid Settlement with terms
identical to the previous opioid settlements. The deadline to opt into the settlements with
the New Parties is September 30, 2025.
ANALYSIS OF ISSUES:
Allocation of Funds
Additional litigation brought by states and cities across the United States against Kroger
National Opioid Settlement has resulted in a proposed settlement totaling approximately
$1.2 billion.
As outlined in the Intrastate Allocation Agreements, Settlement Fund payments due to
the State of California are allocated as follows: 15% to the State Fund; 70% to the
California Abatement Accounts Fund; and 15% to the California Subdivision Fund. This
results in the State receiving 15% of the payments allocated to California and local
subdivisions receiving the remaining 85%. The percentages paid out to the California
Subdivision Fund are reserved for entities that participated in the litigation of the claims
giving rise to the settlement agreements. The percentages paid out to local subdivisions
that did not litigate but chose to opt into the settlements come from the share of the
settlement proceeds that are placed in the California Abatement Accounts Fund (70% of
the total allocated to the State). Essentially, this means that the City of Arroyo Grande, if
it chooses to opt into the settlement, is entitled to receive a percentage share from the
California Abatement Accounts Fund. Of the amounts above, California is to receive
approximately $440 million and is to distribute these funds pursuant to intrastate
allocation agreements for the new settlement.
1 https://pub-arroyogrande.escribemeetings.com/FileStream.ashx?DocumentId=553
2 https://pub-arroyogrande.escribemeetings.com/filestream.ashx?DocumentId=6230
3 https://pub-arroyogrande.escribemeetings.com/filestream.ashx?DocumentId=11834
Page 38 of 98
Item 9.c.
City Council
Opting into Settlement Agreements with Distributors of Opioids; Purdue Pharma,
L.P. National Opioid Settlement
August 26, 2025
Page 3
The City of Arroyo Grande has been allocated 0.024% of the approximate $440,000,000
total settlement amount, which is equal to $73,920. It should be noted that this amount is
the maximum amount that the City can receive from this settlement. In order to encourage
maximum participation, the amount of funds to be paid to each government entity is tied
to the overall number of government entities that opt into the settlements. The more
government entities opt in, the higher the amount that the City will receive. The final
amount to be received by the City will be finalized after the September 30th deadline,
when the total participation in the settlement can be determined. This total amount will be
disbursed over a period of 15 years, with payments decreasing as each settlement
finishes paying out.
The default distribution of funds in the settlement agreements provides th at the funds will
go directly to the county in which a city is located. A city can elect to have its funds
delivered directly to the city by providing notice in the settlement agreements. Additionally,
a city within a county may opt in or out of direct payment at any time, and it may also elect
direct payment of only a portion of its share, with the remainder going to the county, by
providing notice to the settlement fund administrators at least sixty days prior to a payment
date.
In deciding whether to allow a city’s funds to go directly to the county in which a city is
located, a city should consider the following: (1) whether the amount of money is
substantial enough for the city to handle it on its own; (2) whether the city offe rs the
services and has the employees to spend the money in accordance with its prescribed
uses; and (3) whether the city wants to engage in the reporting requirements over the
course of the next sixteen years (fifteen years of distribution and an additional year
following final distribution).
Use of Received Funds
Similar to the other opioid settlements, funds received from this additional settlement must
be used for future opioid remediation or abatement. For instance, participating
subdivisions may use funds for areas such as services to treat opioid use disorder;
support people in treatment and recovery; connect people to care; address needs of
criminal justice-involved persons; address the needs of pregnant or parenting women and
their families, including babies with neonatal abstinence syndrome; prevent over -
prescribing and ensure appropriate prescribing and dispensing of opioids; prevent misuse
of opioids; prevent overdose deaths and other harms; provide leadership, planning, and
coordination of programs; provide training; and conduct research.
In addition to these requirements, there is also a time limit on the spending of received
funds. If funds are not expended or encumbered within five years of receipt and in
accordance with the settlement agreements and the Intrastate Allocation Agreements,
the funds are required to be transferred back to the State.
Page 39 of 98
Item 9.c.
City Council
Opting into Settlement Agreements with Distributors of Opioids; Purdue Pharma,
L.P. National Opioid Settlement
August 26, 2025
Page 4
Management of Funds
Each county and city that receives payment of funds from the settlements must prepare
written reports at least annually regarding the use of those funds until the funds are fully
expended and for one year thereafter. Each county and city will need to track all deposits
and expenditures. These reports will also include a certification that all funds received
have been used in compliance with the allocation agreements. The California Department
of Healthcare and Services (“DHCS”) may review these reports in order to determine
compliance with the settlement agreements and the Intrastate Allocation Agreement.
If the DHCS determines that a participating subdivision’s use of abatement funds is
inconsistent with the settlement agreements or Intrastate Allocation Agreements, the
parties are required to meet and confer. If the meet and confer process does not provide
a resolution, the DHCS may conduct an audit, which can lead to a court action if the
matter is still not resolved after an audit.
Opting In
The City must opt into the settlements by September 30, 2025, which requires the City to
release its claims against the New Party. If the City takes no action, it will have opted out
of the settlements, and its designated funds will flow to the State. The City would still have
the opportunity to bring its own action against the New Party.
A full copy of the settlement agreement is available through the following link:
https://nationalopioidsettlement.com/wp-content/uploads/2025/06/7592-Govt-Entity-
Direct-Shareholder-Settlement-Agreement-GESA.pdf
To opt in to the settlements, Council may approve the proposed resolution that is included
in this staff report as Attachment 1. That resolution will authorize the City Manager to
execute the settlement release form that is included as Attachment 2.
ALTERNATIVES:
The following alternatives are provided for the Council’s consideration:
1. Opt into the settlements and elect to receive the payments directly (subject to the
use and reporting requirements);
2. Opt into the settlements, but allow the County to receive the payments (City
would not be responsible for any use/reporting requirements and the money
would stay within the County); Provide other direction to staff;
3. Do not opt-into the settlements; or
4. Provide other direction to staff .
ADVANTAGES:
Approval of the settlement agreement will provide funding for training, programs, and
interventions to avoid drug overdoses and addiction in the City.
Page 40 of 98
Item 9.c.
City Council
Opting into Settlement Agreements with Distributors of Opioids; Purdue Pharma,
L.P. National Opioid Settlement
August 26, 2025
Page 5
DISADVANTAGES:
Approval of the settlement agreement will increase reporting requirements for the City
elects to retain the funding rather than allocate it to the County. However, should reporting
requirements prove to be too onerous, the City may allocate its funding to the County to
support its addiction programs.
ENVIRONMENTAL REVIEW:
No environmental review is required for this item. Adopting the Resolution opting-into the
settlement agreements is not a project subject to the California Environmental Quality Act
(“CEQA”) because the adoption in itself has no potential to result in eith er a direct, or
reasonably foreseeable indirect, physical change in the environment. (State CEQA
Guidelines, §§ 15060, subd. (b)(2)-(3), 15378.)
PUBLIC NOTIFICATION AND COMMENTS:
The Agenda was posted at City Hall and on the City’s website in accordance w ith
Government Code Section 54954.2.
ATTACHMENTS:
1. Proposed Resolution
2. Opt-in Release Form
Page 41 of 98
ATTACHMENT 1
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ARROYO
GRANDE AUTHORIZING THE CITY MANAGER TO ENTER INTO THE
NATIONAL OPIOID SETTLEMENT AGREEMENT WITH OPIOID
DISTRIBUTORS, PURDUE PHARMA, L.P., AND THE SACKLER FAMILY
WHEREAS, the United States is facing an ongoing public health crisis of opioid abuse,
addiction, overdose, and death, forcing the State of California and California counties and
cities to spend billions of dollars each year to address the direct consequences of this
crisis; and
WHEREAS, pending in the U.S. District Court for the Northern District of Ohio is a
multidistrict litigation (“MDL”) being pursued by numerous public entity plaintiffs agains t
the manufacturers and distributors of various opioids based on the allegation that the
defendants’ unlawful conduct caused the opioid epidemic; and
WHEREAS, in 2024, the State of California entered into a Subdivision Agreement
Regarding Distribution and Use of Settle Funds with Purdue National Opioid Settlement
with terms identical to the previous opioid settlements; and
WHEREAS, Purdue shall be referred in this Resolution as the “Settling Defendant”; and
WHEREAS, as part of the settlements with the Settling Defendant, local subdivisions,
including certain cities, that are not plaintiffs in the MDL may participate in the settlements
in exchange for a release of the Settling Defendant; and
WHEREAS, copies of the proposed terms have been set forth in the Master Settlement
Agreements with the Settling Defendant; and
WHEREAS, California local governments in the MDL have engaged in extensive
discussions with the State Attorney General’s Office (“AGO”) as to how the California
Opioid Funds will be allocated, which has resulted in the Proposed California State -
Subdivision Agreements Regarding Distribution and Use of Settlement Funds (“Allocation
Agreement”) from the settlements with the Settling Defendant; and
WHEREAS, copies of the Allocation Agreement for the settlement with the Settling
Defendant have been provided with this Resolution; and
WHEREAS, the Allocation Agreement allocate the California Opioid Funds as follows:
15% to the State Fund; 70% to the Abatement Accounts Fund; and 15% to the Subdivision
Fund. For the avoidance of doubt, all funds allocated to California f rom the Settlements
shall be combined pursuant to the Allocation Agreement, and 15% of total from each
settlement shall be allocated to the State of California (the “State of California Allocation”),
Page 42 of 98
RESOLUTION NO.
PAGE 2
70% to the California Abatement Accounts Fund (“CA Abate ment Accounts Fund”), and
15% to the California Subdivision Fund (“CA Subdivision Fund”); and
WHEREAS, under the Master Settlement Agreement, certain local subdivisions that did
not file a lawsuit against the Settlement Defendant may qualify to participate in the
settlements and obtain funds from the Abatement Account Fund; and
WHEREAS, the City is eligible to participate in the Settlement and become a CA
Participating Subdivision; and
WHEREAS, the funds in the CA Abatement Accounts Fund (the 70% allocation) will be
allocated based on the allocation model developed in connection with the proposed
negotiating class in the National Prescription Opiate Litigation (MDL No. 2804), as
adjusted to reflect only those cities and counties that are eligible, based on population or
litigation status, to become a CA Participating Subdivision (those above 10,000 in
population). The percentage from the CA Abatement Accounts Fund allocated to each
CA Participating Subdivision is set forth in Appendix 1 to the Allocation Agreements and
provided to the City Council with this Resolution. The City’s share of the CA Abatement
Accounts Fund will be a product of the total in the CA Abatement Accounts Fund
multiplied by the City’s percentage set forth in Appendix 1 of the Allocation Agreements
(the “Local Allocation”); and
WHEREAS, a CA Participating Subdivision that is a city will be allocated its Local
Allocation share as of the date on which it becomes a Participating Subdivision. The Local
Allocation share for a city that is a CA Participating Subdivision will be paid to the county
in which the city is located, unless the city elects to take a direct election of the settlement
funds, so long as: (a) the county is a CA Participating Subdivision, and (b) the city has
not advised the Settlement Fund Administrator that it requests direct payment at least 60
days prior to a Payment Date; and
WHEREAS, it the intent of this Resolution is to authorize the City Manager to enter into
the Master Settlement Agreement with the Settling Defendant by executing the
Participation and the Allocation Agreements by executing the signature pages t o those
agreements.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
ARROYO GRANDE AS FOLLOWS:
SECTION 1. The above recitals are true and correct and are incorporated herein by this
reference.
SECTION 2. The City Manager is authorized to settle and release the City’s claims
against the Settling Defendant in exchange for the consideration set forth in the
Settlement Agreement and Allocation Agreements, including but not limited to, taking the
following measures:
Page 43 of 98
RESOLUTION NO.
PAGE 3
1. The execution of the Participation Agreement with the Settling Defendant and
any and all documents ancillary thereto.
2. The execution of the Proposed California State-Subdivision Agreement
Regarding Distribution and Use of Settlement Funds with the Settling
Defendant by executing the signature pages to those Allocation Agreements.
3. Notify the Settlement Fund Administrator that the City requests a direct
payment under the Allocation Agreements at least 60 days prior to the Payment
Date in the Settlement Agreements.
SECTION 3. CEQA. That the City Council finds this Resolution is not subject to the
California Environmental Quality Act (CEQA) in that the activity is covered by the general
rule that CEQA applies only to projects which have the potential for causing a significant
effect on the environment. Where it can be seen with certainty, as in this case, that there
is no possibility that the activity in question may have a significant effect on the
environment, the activity is not subject to CEQA (State CEQA Guidelines, §§ 15060 ,
subd. (c)(2)-(3), 15378.)
SECTION 4. Severability. If any provision of this Resolution or the application thereof to
any person or circumstance is held invalid, such invalidity shall not affect other provisions
or applications, and to this end the provisions of this Resolution are declared to be
severable.
SECTION 5. Effective Date. This Resolution shall become effective immediately.
On motion of Council Member , seconded by Council Member ,
and on the following roll call vote, to wit:
AYES:
NOES:
ABSENT:
the foregoing Resolution was passed and adopted this 26th day of August, 2025.
Page 44 of 98
RESOLUTION NO.
PAGE 4
CAREN RAY RUSSOM, MAYOR
ATTEST:
JESSICA MATSON, CITY CLERK
APPROVED AS TO CONTENT:
MATTHEW DOWNING, CITY MANAGER
APPROVED AS TO FORM:
ISAAC ROSEN, CITY ATTORNEY
Page 45 of 98
K-1
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: State:
Authorized Official:
Address 1:
Address 2:
City, State, Zip:
Phone:
Email:
The governmental entity identified above (“Governmental Entity”), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to that certain
Governmental Entity & Shareholder Direct Settlement Agreement accompanying this
participation form (the “Agreement”)1, and acting through the undersigned authorized official,
hereby elects to participate in the Agreement, grant the releases set forth below, and agrees as
follows.
1.The Governmental Entity is aware of and has reviewed the Agreement, and agrees that by
executing this Participation and Release Form, the Governmental Entity elects to
participate in the Agreement and become a Participating Subdivision as provided therein.
2.The Governmental Entity shall promptly after the Effective Date, and prior to the filing of
the Consent Judgment, dismiss with prejudice any Shareholder Released Claims and
Released Claims that it has filed. With respect to any Shareholder Released Claims and
Released Claims pending in In re National Prescription Opiate Litigation, MDL No. 2804,
the Governmental Entity authorizes the Plaintiffs’ Executive Committee to execute and file
on behalf of the Governmental Entity a Stipulation of Dismissal with Prejud ice
substantially in the form found at https://nationalopioidsettlement.com.
3.The Governmental Entity agrees to the terms of the Agreement pertaining to Participating
Subdivisions as defined therein.
4.By agreeing to the terms of the Agreement and becoming a Releasor, the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary
payments beginning following the Effective Date.
5.The Governmental Entity agrees to use any monies it receives through the Agreement
solely for the purposes provided therein.
6.The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity’s state where the Consent Judgment is filed for purposes limited to that court’s role
as and to the extent provided in, and for resolving disputes to the extent provided in, the
1 Capitalized terms used in this Exhibit K but not otherwise defined in this Exhibit K have the meanings given to
them in the Agreement or, if not defined in the Agreement, the Master Settlement Agreement.
ATTACHMENT 2
Page 46 of 98
K-2
Agreement. The Governmental Entity likewise agrees to arbitrate before the National
Arbitration Panel as provided in, and for resolving disputes to the extent otherwise
provided in, the Agreement.
7. The Governmental Entity has the right to enforce the Agreement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Agreement, including without limitation all provisions of Article 10
(Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Subdivision Releasor, to the maximum extent of its authority, for good
and valuable consideration, the adequacy of which is hereby confirmed, the Shareholder
Released Parties and Released Parties are, as of the Effective Date, hereby released and
forever discharged by the Governmental Entity and its Subdivision Releasors from: any
and all Causes of Action, including, without limitation, any Estate Cause of Action and any
claims that the Governmental Entity or its Subdivision Releasors would have presently or
in the future been legally entitled to assert in its own right (whether individually or
collectively), notwithstanding section 1542 of the California Civil Code or any law of any
jurisdiction that is similar, comparable or equivalent thereto (which shall conclusively be
deemed waived), whether existing or hereinafter arising, in each case, (A) directly or
indirectly based on, arising out of, or in any way relating to or concerning, in whole or in
part, (i) the Debtors, as such Entities existed prior to or after the Petition Date, and their
Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv) Covered Conduct and (B) as
to which any conduct, omission or liability of any Debtor or any Estate is the legal cause
or is otherwise a legally relevant factor (each such release, as it pertains to the Shareholder
Released Parties, the “Shareholder Released Claims ”, and as it pertains to the Released
Parties other than the Shareholder Released Parties, the “Released Claims”). For the
avoidance of doubt and without limiting the foregoing: the Shareholder Released Claims
and Released Claims include any Cause of Action that has been or may be asserted against
any Shareholder Released Party or Released Party by the Governmental Ent ity or its
Subdivision Releasors (whether or not such party has brought such action or proceeding )
in any federal, state, or local action or proceeding (whether judicial, arbitral, or
administrative) (A) directly or indirectly based on, arising out of, or in any way relating to
or concerning, in whole or in part, (i) the Debtors, as such Entities exis ted prior to or after
the Petition Date, and their Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv)
Covered Conduct and (B) as to which any conduct, omission or liability of any Debtor or
any Estate is the legal cause or is otherwise a legally relevant factor.
9. As a Releasor, the Governmental Entity hereby absolutely, unconditionally, and
irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be brought,
filed, or claimed, or to otherwise seek to establish liability for any Shareholder Released
Claims or Released Claims against any Shareholder Released Party or Released Party in
any forum whatsoever, subject in all respects to Section 9.02 of the Master Settlement
Agreement. The releases provided for herein (including the term “Shareholder Released
ATTACHMENT 2
Page 47 of 98
K-3
Claims” and “Released Claims”) are intended by the Governmental Entity and its
Subdivision Releasors to be broad and shall be interpreted so as to give the Shareholder
Released Parties and Released Parties the broadest possible release of any liability relating
in any way to Shareholder Released Claims and Released Claims and extend to the full
extent of the power of the Governmental Entity to release claims. The Agreement shall be
a complete bar to any Shareholder Released Claim and Released Claims.
10. To the maximum extent of the Governmental Entity’s power, the Shareholder Released
Parties and the Released Parties are, as of the Effective Date, hereby released and
discharged from any and all Shareholder Released Claims and Released Claims of the
Subdivision Releasors.
11. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Agreement.
12. In connection with the releases provided for in the Agreement, each Governmental Entity
expressly waives, releases, and forever discharges any and all provisions, rights, and
benefits conferred by any law of any state or territory of the United States or other
jurisdiction, or principle of common law, which is similar, comparable, or equivalent to
§ 1542 of the California Civil Code, which reads:
General Release; extent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that, if known by him or her, would
have materially affected his or her settlement with the debtor or released
party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Shareholder Released Claims or such
other Claims released pursuant to this release, but each Governmental Entity hereby
expressly waives and fully, finally, and forever settles, releases and discharges, upon the
Effective Date, any and all Shareholder Released Claims or such other Claims released
pursuant to this release that may exist as of such date but which Releasors do not know or
suspect to exist, whether through ignorance, oversight, error, negligence or through no fault
whatsoever, and which, if known, would materially affect the Governmental Entities’
decision to participate in the Agreement.
13. Nothing herein is intended to modify in any way the terms of the Agreement, to which
Governmental Entity hereby agrees. To the extent any portion of this Participation and
Release Form not relating to the release of, or bar against, liability is interpreted differently
from the Agreement in any respect, the Agreement controls.
14. Notwithstanding anything to the contrary herein or in the Agreement, (x) nothing herein
shall (A) release any Excluded Claims or (B) be construed to impair in any way the rights
and obligations of any Person under the Agreement; and (y) the Releases set forth herein
shall be subject to being deemed void to the extent set forth in Section 9.02 of the Master
Settlement Agreement.
ATTACHMENT 2
Page 48 of 98
K-4
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature: _____________________________
Name: _____________________________
Title: _____________________________
Date: _____________________________
ATTACHMENT 2
Page 49 of 98