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Fourth District Holds CEQA Challenge To Ministerial Approval Of Development Project Modifications Barred By Res Judicata, Water...

“Birds of a feather flock together.” — Proverb - The Fourth District Court of Appeal (Div. 2) affirmed a judgment entered after the sustaining of a demurrer without leave, holding that a mandate action brought by The...more

Arguing Impacts By Proxy: Fourth District Holds CEQA Does Not Require EIR Absent Evidence That Subdivision Approval Actually...

In an opinion filed August 10, and later ordered published on September 7, 2018, the Fourth District Court of Appeal (Div. 2) affirmed a judgment denying Friends of Riverside’s Hills’ (FRH) writ petition challenging a...more

More Mild Than Wild: Legislature Tinkers With Modestly Reforming Scope Of CEQA Analysis In Two New Laws

On September 7, 2018, Governor Brown signed two bills amending CEQA in relatively minor ways that will become effective January 1, 2019. AB 2341 (Chapter 298) (Mathis) adds Public Resources Code § 21081.3 to provide that...more

Second District Applies CEQA’s “Subsequent Review” Rules to Uphold EIR Addendum for Revised Target Superstore Project Including...

In a lengthy published opinion filed August 23, 2018, the Second District Court of Appeal reversed the trial court’s judgment, and upheld the City of Los Angeles’ addendum to a prior project-level EIR for a Target Superstore...more

“Growing Pains”: First District Holds Program EIR for San Francisco’s General Plan Housing Element Amendment Complies with CEQA

In a lengthy published opinion filed on August 22, 2018, the First District Court of Appeal (Div. 4) affirmed the trial court’s judgment rejecting various CEQA challenges to the City of San Francisco’s (“City”) Program EIR...more

Context Matters: First District Holds CEQA Requires EIR, Not MND, To Analyze Mixed-Use Project’s Potentially Significant Aesthetic...

In an opinion filed July 16, and belatedly ordered published on August 9, 2018, the First District Court of Appeal (Division 5) affirmed the trial court’s judgment setting aside the City of Fremont’s approvals of a mixed...more

Second District Holds CEQA Does Not Apply to San Luis Obispo County’s Issuance of Well Construction Permits Under Its Ministerial...

In an opinion filed June 28, and later ordered published on July 27, 2018, the Second District Court of Appeal (Div. 6) affirmed the trial court’s judgment dismissing on demurrer a writ petition seeking to compel the County...more

Filtering The CEQA Noise: First District Upholds Santa Rosa’s Negative Declaration For “Dream Center” Youth Housing Project, Holds...

A development project’s potential noise impacts can implicate complex and technical issues under CEQA, particularly where those impacts are asserted, in litigation by project opponents challenging a negative declaration, as...more

First District Rejects Numerous CEQA Challenges To RFEIR For Propane Recovery Project At Phillips 66 Company’s Rodeo Oil Refinery,...

In an opinion filed March 20, and later certified for publication on April 12, 2018, the First District Court of Appeal (Division 3) affirmed a limited peremptory writ of mandate issued by the Contra Costa County Superior...more

Redrawing CEQA’s “Parking” Lines? Second District Holds Parking Impacts of Covina Mixed-Use, Transit-Oriented Infill Project Are...

SB 743 was enacted in 2013 to further California’s efforts to reduce GHG emissions by encouraging transit-oriented, infill development – a strategy announced in SB 375, the “Sustainable Communities and Climate Protection Act...more

CEQA Does Not Require City’s General Plan Update EIR to Address Urban Decay Based on Broker’s Speculative Opinion Concerning...

In an opinion filed on January 4, and later certified for partial publication on January 30, 2018, the Fifth District Court of Appeal affirmed a trial court judgment rejecting appellant’s claim that the EIR for the City of...more

First District Holds CEQA Exhaustion Requirements Don’t Apply to Attorney General, Upholds Adequacy of Most of EIR’s Analysis for...

In a lengthy, partially published opinion filed January 12, 2018, the First District Court of Appeal (Division 3) partly affirmed, but in large part reversed, the trial court’s judgment granting a writ of mandate directing...more

Second District Holds Melrose Triangle Project EIR’s Alternatives Analysis and Responses to Comments Comply with CEQA, Upholds...

In an opinion filed on November 30, and belatedly ordered published on December 22, 2017, the Second District Court of Appeal, Division 1, affirmed the trial court’s judgment denying all CEQA challenges asserted by...more

The Past Year In CEQA Case Law: A Quick Look Back at 2017

As we move into a brand new year of tracking CEQA developments, it seems like an appropriate time to survey and briefly recap some of the many significant published case law developments that occurred over the past...more

CEQA Remedies Statute Authorizes Writ Partially Decertifying EIR and Leaving Project Approvals In Place

In a partially published opinion filed December 4, 2017, the Second District Court of Appeal affirmed the trial court’s post-remand judgment and held that CEQA’s remedies statute – Public Resources Code § 21168.9 – allows a...more

Fifth District Holds Cap-And-Trade Program Compliance Supports Refinery Project EIR’s Conclusion That GHG Emissions Are Less Than...

In a lengthy, partially published opinion filed November 21, 2017, the Fifth District Court of Appeal addressed four CEQA challenges asserted by plaintiffs and appellants (“AIR”) to the sufficiency of Kern County’s 2014 Final...more

SANDAG RTP/SCS EIR Redux: Is Fourth District’s Published Opinion on Remand Constructive CEQA Compliance Lesson or Moot Exercise?

When it comes to CEQA cases, some courts don’t seem to know when to stop beating a dead horse. So it may be with the Fourth District Court of Appeal’s 43-page, published, 2-1 majority decision, accompanied by a 4-page...more

Power to the Public: DEIR’s Failure to Identify Proposed Project Among Handful of Vastly Different Analyzed Alternatives Violates...

In a published opinion filed November 15, 2017, the First District Court of Appeal (Division 5) affirmed the trial court’s order granting a petition for writ of mandate setting aside the California Department of Parks and...more

Leaving Well Enough Alone: Governor Brown Vetoes CEQA Bill That Would Mandate Lead Agencies To File NOEs For Projects Approved As...

On October 15, 2017, Governor Brown vetoed SB 80 (Wieckowski), a bill that would have added to CEQA’s already detailed notice requirements. Specifically, SB 80 would have amended Public Resources Code §§ 21092.2, 21092.3,...more

Keeping CEQA In Its Lane: First District Holds Substantial Evidence Supports EIR’s Conclusion That “Urban Decay” Is Not Reasonably...

In 15-page opinion filed on September 15, and later certified for publication on October 16, 2017, the First District Court of Appeal affirmed the trial court’s judgment denying a writ petition challenging the Judicial...more

First District Upholds CEQA Categorical Exemption for Approval of Planned Parenthood Clinic in City of South San Francisco,...

When a lead agency finds a project approval to be categorically exempt from CEQA, this determination at the initial step of CEQA’s multi-tiered process necessarily includes an implied finding that no exceptions to the...more

Sixth District Holds Project’s Consistency with General Plan Is Not a CEQA Issue, Upholds Trial Court’s Interlocutory Remand for...

In an opinion originally filed on July 31, and belatedly ordered partially published on August 24, 2017, the Sixth District Court of Appeal affirmed the trial court’s judgment denying a writ petition brought by a citizens...more

Fourth District Rejects CEQA Challenge to College District’s Entry into Land Acquisition Agreement Prior to Preparing EIR Due to...

In a published decision filed August 8, 2017, the Fourth District Court of Appeal affirmed the trial Court’s judgment dismissing a CEQA action brought by two individuals (“Appellants”) against the Mt. San Jacinto Community...more

Supreme Disappointment: High Court’s Narrow Opinion In SANDAG RTP/SCS EIR Case Offers Little Guidance On CEQA GHG Analysis

On July 13, 2017, the California Supreme Court rendered a 6-1 decision holding that the San Diego Association of Governments’ (SANDAG) 2011 EIR for its Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)...more

First District Holds CEQA Action Can Be Brought Directly Against Local Air District to Challenge “Authority to Construct” Issued...

In an opinion filed March 23, and belatedly modified and ordered published on May 25, 2017, the First District Court of Appeal reversed the trial court’s dismissal of a plaintiff environmental group’s (“Friends”) CEQA action...more

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