2023 served up roughly the same number of published appellate CEQA cases as 2022 with a defense win percentage of over 80 percent, which has been the case in many, if not all, of the past ten years. A prominent theme of upholding exemptions emerged, in particular the infill exemption and the commonsense exemption which are reviewed with the application of the substantial evidence standard of review. The cases also demonstrate that agencies often rely on multiple exemptions as a “belt and suspenders” defense tactic. The courts sanctioned the use of exemptions, striking down only one infill exemption citing a lack of evidence to support the agency’s conclusions in that instance and underscoring the necessity of preparing detailed findings and citing to supportive evidence when using an exemption. (United Neighborhoods for Los Angeles v. City of Los Angeles (2023) 93 Cal.App.5th 1074.)