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Third District Holds CEQA Does Not Authorize “Remedy” of “Limited EIR” To Augment Deficient MND; Rather, Full EIR Must Be Prepared...

In a partially published opinion filed on November 3, 2021, involving the CEQA review for a bed and breakfast/commercial event project proposed on property within a Yolo County agricultural zone, the Third District Court of...more

“Let’s Not Complicate Things”: Second District Holds Trial Court Properly Exercised Its Discretion In Denying Union’s Permissive...

In a published opinion filed November 4, 2021, the Second Appellate District (Div. 8) affirmed the Los Angeles County Superior Court’s order denying International Longshore and Warehouse Union Locals 13, 63, and 94’s...more

Fourth District Affirms Judgment Upholding CEQA Class 32 Infill Exemption For Costco Gas Station/Parking Lot Project Within...

In an opinion filed September 28, and certified for publication on October 26, 2021, the Fourth District Court of Appeal (Div. 3) affirmed a judgment denying a writ petition challenging the City of Tustin’s finding that a...more

A Teaching Moment? First District Affirms CEQA Action Demurrer Order Finding Late-Joined Developers of UC Berkeley Campus Project...

In a published opinion filed October 21, 2021, the First District Court of Appeal affirmed the trial court’s order finding the real party developers of a UC Berkeley campus development project – undertaken for the...more

A Decade of CEQA Developments

On September 13, 2011, I began the endeavor of writing Miller Starr Regalia’s CEQA Developments blog.  Ten years and 358 blog posts later, it continues to be a challenging and rewarding task.  Since my inaugural post (which...more

Fifth District Holds Issue Exhaustion Not Required Where Agency Gave No Notice of Intent To Rely On CEQA Exemption Prior to...

In a published decision filed August 17, 2021, the Fifth District Court of Appeal affirmed the trial court’s judgment directing issuance of a writ of mandate ordering Inyo County to vacate three resolutions of necessity that...more

8/26/2021  /  CEQA , Landfills , Standard of Review

Flunking CEQA’s “Fair Argument” Test: Third District Affirms Judgment Upholding MND for El Dorado County Bridge Replacement...

In a partially published unanimous opinion filed June 16, 2021, authored by a jurist who is also a noted CEQA expert (Acting Presiding Justice Ronald Robie), the Third District Court of Appeal affirmed the trial court’s...more

Third District Affirms Judgment Upholding State Lands Commission’s Supplemental EIR For Desalination Plant Lease Modification,...

In a lengthy opinion filed April 8, and ordered published on May 7, 2021, the Third District Court of Appeal affirmed a judgment rejecting a number of CEQA challenges to the California State Land Commission’s (Lands...more

First District Affirms Judgment Rejecting CEQA and General Plan Consistency Challenges to Napa County’s EIR for Syar Quarry...

In an 85-page opinion filed March 25, and modified and certified for partial publication on April 23, 2021, the First District Court of Appeal affirmed the Napa County Superior Court’s judgment denying a writ petition...more

Third Time Is Not The Charm: Fourth District Affirms Judgment Setting Aside San Diego County’s Climate Action Plan And Related...

In a mammoth 132-page published opinion (with an additional five pages of appendices) filed on June 12, 2020, the Fourth District Court of Appeal (Division One) mostly affirmed the trial court’s judgment invalidating San...more

Supreme Court Denies Review And Depublishes CEQA Subsequent Review/“Spot-Zoning” Case Involving Partially Built Los Angeles Target...

On November 20, 2018, in response to a petition for review filed by the Target Superstore project’s opponent, plaintiff (and respondent on appeal) Citizens Coalition Los Angeles, the California Supreme Court denied review and...more

Fourth District Rejects CEQA Challenge To San Diego’s Use of Existing Facilities Categorical Exemption For Mission Beach Amusement...

In an opinion filed December 27, 2018, and later ordered published on January 15, 2019, the Fourth District Court of Appeal (Div. 1) affirmed the trial court’s judgment rejecting CEQA and other challenges to the City of San...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 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

Fourth District Holds Substantial Evidence Supports City of San Diego’s Rejection of MND and Denial of Minor Residential...

In a short opinion filed May 17, 2017, and belatedly ordered published (for unknown reasons) just six days later, the Fourth District Court of Appeal reversed the trial court’s judgment granting a writ of mandate that set...more

First District Holds Sonoma County Vineyard Development (VESCO) Permit was Ministerial Approval Exempt from CEQA

On April 21, 2017, the First District Court of Appeal filed a 22-page published opinion providing significant guidance and analysis concerning the critical, but sometimes elusive, distinction between “discretionary” project...more

Completing the Loop Without Reinventing the Wheel: First District Holds 1998 EIR Adequate Without Further CEQA Review to Analyze...

In an opinion filed November 29, and belatedly ordered published on December 22, 2016, the First District Court of Appeal affirmed the trial court’s denial of a writ petition challenging on CEQA grounds the San Francisco...more

Slam Dunked! First District Rejects All CEQA And Land Use Challenges To Golden State Warriors Event Center Project And EIR In...

In a lengthy published opinion filed November 29, 2016, the First District Court of Appeal rejected all legal challenges to the City of San Francisco’s Final Supplemental Environmental Impact Report (FSEIR) and related land...more

Wither Subsequent Review? Supreme Court Again Weighs In On CEQA Subsequent Review Standards Following Negative Declarations –...

On November 22, 2016, the California Supreme Court issued a significant Order granting review in Coastal Hills Rural Preservation v. County of Sonoma (2016) 2 Cal.App.5th 1234, and also transferring the matter back to the...more

Supreme Court Addresses CEQA Subsequent Review Rules in San Mateo Gardens Case

The California Supreme Court provided needed clarification to some aspects of the operation of CEQA’s “subsequent review” rules (Pub. Resources Code, § 21166; CEQA Guidelines, § 15162) in its highly anticipated opinion, filed...more

Supreme Court Depublishes Quirky Fourth District CEQA/General Plan Decision

On August 17, 2016, the California Supreme Court ordered the Fourth District’s opinion in People for Proper Planning v. City of Palm Springs (2016) 247 Cal.App.4th 640 to be depublished, rendering it unciteable and of no...more

Sixth District Holds CEQA’s “Fair Argument” Test Inapplicable To City Of San Jose’s Discretionary Determination That 1922 Wooden...

A project that may cause a substantial adverse change in the significance of a “historical resource” may, for that reason, have a significant effect on the environment for purposes of CEQA. (Pub. Resources Code, § 21084.1.)...more

The Plot Thickens: California Supreme Court Vacates Submission Of Just-Argued CEQA Subsequent Review Case, Orders Supplemental...

In orders issued May 11, 2016, one week after the May 4 oral argument and submission of the cause for decision, the California Supreme Court vacated the submission and ordered supplemental briefing in Friends of the Collage...more

Fourth District Rejects CEQA Challenges To Large Mojave Desert Groundwater Pumping Project In Separate Published Opinions

In two opinions filed May 10, 2016 (one partially and the other fully published), the Fourth District Court of Appeal rejected a number of CEQA and other challenges to a project proposing to pump 50,000 acre-feet of...more

Fourth District Addresses CEQA Baseline Issues In Partially Published Opinion Upholding EIR For Carlsbad Shopping Mall Renovation

In an opinion filed September 10, and later ordered partially published on October 9, 2015, the Court of Appeal affirmed the substance of a judgment upholding an EIR for a regional shopping center renovation project in...more

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