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

Miller Starr Regalia

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 approvals that are subject to CEQA and “ministerial” ones that are exempt from it.  Sierra Club, et al. v. County of Sonoma (Ronald and Ernest Ohlson, dba Ohlson Ranch, Real Parties in Interest) (1st Dist., Div. 1, 2017) ___ Cal.App.5th  ___. (As a matter of disclosure, I represent the real parties, the Ohlsons, in this action.)

Nature of the Action and The Court of Appeal’s Holding

The case involved a challenge by the Sierra Club and other environmental group plaintiffs (“Appellants”) to the Sonoma County Agricultural Commissioner’s issuance of a vineyard development permit to the owners of Ohlson Ranch under the provisions of County’s Grading, Drainage, and Vineyard and Orchard Site Development Ordinance (commonly known as “VESCO”).  The Commissioner determined the VESCO permit, which authorized development of a 54-acre vineyard on the Ohlsons’ remote western Sonoma County ranch, was a ministerial approval and therefore exempt from CEQA review.  Appellants’ action challenged this determination, contending VESCO contains vague, subjective standards for permit issuance that confer discretion on the Commissioner and that this rendered his permit approval decision – and all VESCO permit approvals, for that matter – subject to CEQA.

The Court of Appeal rejected Appellants’ arguments. It affirmed the trial court’s judgment denying their writ petition, and summarized its key holdings as follows:  “Although the ordinance may allow the Commissioner to exercise discretion when issuing erosion-control  permits in some circumstances, petitioners fail to show that the Commissioner improperly determined that issuing the Ohlsons’ permit was ministerial.  Most of the ordinance’s provisions that potentially confer discretion did not apply to the Ohlsons’ project, and petitioners fail to show that the few that might apply conferred the ability to mitigate potential environmental impacts to any meaningful degree.”

Factual and Regulatory Background, and Litigation Posture

As relevant background, Sonoma County grape growers could plant or replant vineyards “as a matter of right” without need of any permit or governmental permission until 2000, when the County enacted the first version of VESCO, which has been amended several times in the years since.  VESCO’s Article 8 requires growers to obtain an erosion-control permit to establish or plant a vineyard.  To do so they must submit plans and specifications meeting certain directives and requirements.  For low-erosion risk (Level I) sites the grower may prepare the plans, but for steeper and higher-erosion risk (Level II) sites, a civil engineer must prepare the plans.  VESCO’s Article 16 sets out substantive standards for conducting grading, drainage improvement, and vineyard and orchard site development, some of which require compliance with BMPs set forth in a separate publication of the Commissioner.

The Ohlsons’ October 2013 application for a Level II erosion-control permit for the 54-acre vineyard contained site maps, an engineer’s drainage report, and a biological-resources report, and indicated the cattle-grazed site included wetland areas and seasonal swales, but no trees or streams.  The application specified in detail the means whereby erosion and drainage were to be controlled and wetlands protected.

The Commissioner visited the site in December 2013 and used a 69-item checklist to review the application for completeness and substantive adequacy, prior to issuing the permit on December 30, 2013.  All items were marked as satisfied or left unmarked as inapplicable, and while the Commissioner sought some corrections or clarifications (which the Ohlsons made) he did not require any substantive changes in the application materials.  Several months after he approved the permit, the Commissioner issued a notice of exemption (NOE) declaring his action was ministerial and thus exempt from CEQA, and Appellants’ suit followed.  (While the opinion notes the trial court rejected Respondents’ and Real Parties’ “various procedural defenses” – which were not specified in the opinion, but which in fact included statute of limitations, mootness, and res judicata/collateral estoppel – the Court of Appeal expressly declined to reach these issues, stating in a footnote:  “We need not address the Ohlsons’ various procedural defenses because we affirm the trial court’s ruling on the substantive merits.”)

Key Takeaways From the Published Opinion

Key takeaways from the Court of Appeal’s opinion include:

  • The Court applied the “prejudicial abuse of discretion” standard of review in “reviewing the Commissioner’s determination, made in the initial step of the three-tiered [CEQA] process, that issuing the Ohlsons’ permit was exempt from CEQA review because the action was ministerial.” Noting that Guidelines § 15268(a) “makes clear that [t]he determination of what is ‘ministerial’ can most appropriately be made by the particular public agency involved based upon its analysis of its own laws, and [that] each public agency should make such determinations either as a part of its implementing regulations or on a case-by-case basis” (also citing Friends of Davis v. City of Davis (2000) 83 Cal.App.4th 1004, 1015; Sierra Club v. Napa County board of Supervisors (2012) 205 Cal.App.4th 162, 178), the Court stated it would review an agency’s related factual determinations for substantial evidence and pure questions of law de novo.
  • In discussing CEQA’s “ministerial exemption” (see Resources Code, § 21080(a), (b)(1)), the Court reviewed the relevant Guidelines (§§ 15357, 15369) and decades of leading case law defining and analyzing the terms “ministerial” and “discretionary,” distilling them and stating: “Courts continue to recognize that actions by a local agency are discretionary when they require the exercise of the administrator’s subjective judgment and are ministerial when they are taken under regulations that allow for little or no exercise of such judgment.”
  • The Court noted “[a]n important elaboration” of ministerial/discretionary analysis is the “functional test” announced in Friends of Westwood, Inc. v. City of Los Angeles (1987) 191 Cal.App.3d 259, which focuses on whether an agency has discretion to require project changes that would mitigate environmental consequences an EIR might reveal. Recent decisions applying Friends of Westwood’s functional test have recognized:  “CEQA does not apply to an agency decision simply because the agency may exercise some discretion in approving the project or undertaking.  Instead[,] to trigger CEQA compliance, the discretion must be of a certain kind; it must provide the agency with the ability and authority to mitigate…environmental damage to some degree.”  (Quoting San Diego Navy Broadway Complex Coalition v. City of San Diego (2010) 185 Cal.App.4th 924, 934, internal quotes omitted.)
  • Noting that VESCO “itself categorically declares that issuing erosion-control permits is ministerial, except when an application seeks exceptions from the established standards[,]” the Court observed that “[b]ecause…a determination whether issuing a permit is ministerial or discretionary generally must be made on the basis of the project’s particular circumstances, we are skeptical of such a categorical declaration.” It found it didn’t have to decide whether VESCO’s “[categorical] declaration is always binding,” however, “because petitioners have not shown that any provisions that arguably grant discretion actually apply to the Ohlsons’ application so as to refute the Commissioner’s determination that issuing the permit was ministerial.”
  • In addressing Appellants’ contentions that a number of specific VESCO provisions called for the exercise of discretion, the Court stated: “We need not decide whether most of the provisions cited by petitioners confer discretion on the Commissioner because they did not apply to the Ohlsons’ application.  The relevant question in evaluating whether the approval of a particular project was discretionary is not whether the regulations granted the local agency some discretion in the abstract, but whether the regulations granted the agency discretion regarding the particular project.  In other words, a regulation cited as conferring discretion must have been relevant to the project.”  In further explaining CEQA’s project-specific focus in this context the Court stated:  “Our review is not directed to the regulations themselves but to the agency’s action in approving the project under those regulations.  Thus, any regulation cited as granting discretion to the agency must actually have applied to the project under review.  If it did not, the agency could not have exercised discretion under that regulation in approving the project.”
  • Applying these rules, the Court noted some of the provisions cited by Appellants were facially inapplicable to the Ohlsons’ project (e.g., those concerning watercourses, lakes and trees, which features were absent from the property), and some were excluded by the Commissioner as inapplicable, or applied only to post-approval vineyard operations and thus played no role in permit issuance.
  • After eliminating the inapplicable VESCO provisions, only 3 potentially relevant ordinance requirements remained: (1) a 50-foot wetlands setback “unless a wetlands biologist recommends a different setback”;  (2) that storm water be diverted “to the nearest practicable disposal location”; and (3) that applicant “[i]ncorporate natural drainage features…whenever possible.”  Even if the language of these provisions arguably conferred some discretion, however, that discretion would still have to be of a certain kind under CEQA’s functional test, i.e., discretion that gives the agency the ability to mitigate environmental damage in a meaningful way.  Deferring to the Commissioner’s determination under the facts here, the Court held Appellants failed to carry their burden of showing these provisions conferred meaningful discretion.
  • In rejecting Appellants’ argument that any kind of discretion was sufficient to trigger CEQA, the Court also pointed out that accepting that “argument would have the perverse effect of discouraging agencies from enacting ordinances, such as the ordinance here, specifically designed to mitigate environmental impacts through a permitting process. … [A]gencies would be motivated to avoid CEQA burdens by simply not enacting such ordinances in the first place.”
  • The Court also rejected Appellants’ argument that the VESCO permit was discretionary because the Ohlsons accepted the Commissioner’s recommendations that they include general mitigation measures not required by the ordinance in their engineering plans. Relying on the holding in Friends of the Juana Briones House v. City of Palo Alto (2010) 190 Cal.App.4th 286, 309 that “conditions voluntarily accepted by a permit applicant but not required under the applicable ordinance did not render the permit discretionary,” the Court stated:  “We decline to hold that the issuance of a permit, otherwise ministerial, is rendered discretionary and therefore subject to further CEQA review because the applicant offers to mitigate potential impacts in ways that are not required.”  Nor did the Court accept Appellants’ argument that the Commissioner’s requests for corrections and clarifications to the Ohlsons’ permit application demonstrated CEQA-triggering discretion; “the simple fact that an agency asks for more information does not establish that the applicant must provide that information before the applicant can compel the issuance of the permit” and Appellants failed to show the corrections and clarifications were significant enough to possibly alleviate adverse environmental impacts.
  • The Court also made some significant observations regarding the general nature of County’s VESCO, finding that “the Commissioner’s consideration of the Ohlsons’ application was confined by a series of finely detailed and very specific regulations. …. While these provisions may grant some discretion, the scope of any such discretion is drastically narrower than that which was conferred by the broad language of the regulations in [People v.] Department of Housing [& Community Dev. (1975) 45 Cal.App.3d 185], Day [v. City of Glendale (1975) 51 Cal.App.3d 817] and Friends of Westwood.  In addition, the provisions here are technical.  A provision that appears to a lay person to grant discretion to an agency might, as understood by a person with technical knowledge, grant little or none in the context of a particular proposed project.”

Implications and Significance of the Decision

Simply put, drawing the line between ministerial and discretionary action is extremely significant – it is the dividing line that determines whether a lead agency’s project approval is exempt from or subject to CEQA.  The Court of Appeal’s opinion applies and elaborates on CEQA’s “functional test” and holds that meaningful discretion – i.e., discretion the exercise of which could actually mitigate otherwise significant project impacts – is required to trigger CEQA compliance obligations.  The opinion discusses the relevant authorities and considerations in making the “ministerial/discretionary” determination, and emphasizes that it is properly analyzed and made in the context of a particular project, and not in the abstract or based on how the agency’s legal controls might be exercised over other projects.  The opinion thus provides significant guidance to agencies drafting or applying land use ordinances intended to establish a ministerial permitting scheme to avoid the burdens of CEQA review, and to project applicants proposing projects under such ordinances.

Written by:

Miller Starr Regalia

Miller Starr Regalia on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.