HomeMy WebLinkAboutCC 2025-09-09_09d Opioid Settlement AgreementItem 9.d.
MEMORANDUM
TO: City Council
FROM: Matthew Downing, City Manager
BY: Nicole Valentine, Director of Administrative Services
SUBJECT: Opting into Settlement Agreements with Manufacturers of Opioids,
National Opioid Settlement
DATE: September 9, 2025
RECOMMENDATION:
1) Adopt a Resolution authorizing the City Manager to enter into the National Opioid
Settlement Agreement with Opioid Manufacturers, Alvogen, Inc., Amneal
Pharmaceuticals Inc., Apotex Corp., Hikma Pharmaceuticals USA, Inc., Indivior Inc.,
Mylan, Sun Pharmaceutical Industries, Inc., and Zydus Pharmaceuticals (USA), Inc.; 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 indire ct,
physical change in the environment. (State CEQA Guidelines, §§ 15060, subd. (c)(2)-(3),
15378.)
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
California is to receive approximately $70 million from the settlements and is required to
distribute these funds pursuant to intrastate allocation agreements for the new
settlements. The City of Arroyo Grande has been allocated 0.024% of the 70% of the $70
million. The City can opt into this settlement and potentially receive up to $11,760 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 40 of 148
Item 9.d.
City Council
Opting into Settlement Agreements with Manufacturers of Opioids, National Opioid
Settlement
September 9, 2025
Page 2
Litigation brought by states and cities across the United State s 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 pro posed 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; 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 the these
parties on April 11, 20232. In 2024, Kroger Co. reached a tentative settlement regarding
its outstanding opioid distribution claim s and the City opted into this settlement on July
23, 20243. On August 26, 20254, the City opted into Settlement Agreements with
Distributors of Opioids; Purdue Pharma, L.P. National Opioid Settlement, as well.
In March 2024, the State of California entered into a Subdivision Agreement Regarding
Distribution and Use of Settlement Funds with the Other Manufacturers National Opioid
Settlement with terms identical to the previous opioid settlements. The deadline to opt
into the settlements with the New Parties is October 8, 2025.
ANALYSIS OF ISSUES:
Allocation of Funds
Additional litigation brought by states and cities across the United States against the
Other Opioid Manufacturers National Opioid Settlement has resulted in a proposed
settlement totaling approximately $720 million dollars.
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 is 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 choose to opt into the settlements comes 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 $70 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
4 https://pub-arroyogrande.escribemeetings.com/filestream.ashx?DocumentId=15701
Page 41 of 148
Item 9.d.
City Council
Opting into Settlement Agreements with Manufacturers of Opioids, National Opioid
Settlement
September 9, 2025
Page 3
The City of Arroyo Grande has been allocated 0.024% of the 70% of the approximate
$70,000,000 total settlement amount, which is equal to $11,760. 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 amount 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 that 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 offers 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.
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Item 9.d.
City Council
Opting into Settlement Agreements with Manufacturers of Opioids, National Opioid
Settlement
September 9, 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 o rder 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 October 8, 2025, which requires the City to
release its claims against the Other Opioid Manufacturers. 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 Other Opioid
Manufacturers.
ALTERNATIVES:
The following alternatives are provided for the Council’s consideration:
Include a brief summary of each feasible alternative availabl e for consideration. It is
important to provide a complete list. Do not exclude potential alternatives simply because
staff believes they will be detrimental.
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);
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.
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
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Item 9.d.
City Council
Opting into Settlement Agreements with Manufacturers of Opioids, National Opioid
Settlement
September 9, 2025
Page 5
requirements prove to become 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 either a direct, or
reasonably foreseeable indirect, physical change in the environment. (State CEQA
Guidelines, §§ 15060, subd. (c)(2)-(3), 15378.)
PUBLIC NOTIFICATION AND COMMENTS:
The Agenda was posted at City Hall and on the City’s website in accordance with
Government Code Section 54954.2.
ATTACHMENTS:
1. Resolution
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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
MANUFACTURERS, ALVOGEN, INC., AMNEAL PHARMACEUTICALS
INC., APOTEX CORP., HIKMA PHARMACEUTICALS USA, INC.,
INDIVIOR INC., MYLAN, SUN PHARMACEUTICAL INDUSTRIES, INC.,
AND ZYDUS PHARMACEUTICALS (USA), INC.
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 against
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 Other Manufacturers National Opioid
Settlement with terms identical to the previous opioid settlements; and
WHEREAS, the Other Manufactuers shall be referred in this Resolution as the “Settling
Defendants”; and
WHEREAS, as part of the settlements with the Settling Defendants, 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 Defendants; and
WHEREAS, copies of the proposed terms have been set forth in the Master Settlement
Agreements with the Settling Defendants; 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 Defendants; and
WHEREAS, copies of the Allocation Agreement for the settlement with the Settling
Defendants have been provided with this Resolution; and
Page 45 of 148
RESOLUTION NO.
PAGE 2
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 from 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”),
70% to the California Abatement Accounts Fund (“CA Abatement 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 Defendants 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 Allocat ion 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 Defendants by executing the
Participation and the Allocation Agreements by executing the signature pages to 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.
Page 46 of 148
RESOLUTION NO.
PAGE 3
SECTION 2. The City Manager is authorized to settle and release the City’s claims
against the Settling Defendants in exchange for the consideration set forth in the
Settlement Agreement and Allocation Agreements, including taking the following
measures:
1. The execution of the Participation Agreement with the Settling Defendants 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
Defendants 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 9th day of September, 2025.
Page 47 of 148
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
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