Citizens Coalition Los Angeles v. City of Los Angeles

The Court of Appeal reversed the trial court's ruling that the city violated the California Environmental Quality Act (CEQA) because the city treated the creation of a new subzone as follow-on to its prior, initial approval of a Target store rather than as an entirely new "project" under CEQA. The court held that the city's ordinance should be examined under Public Resources Code section 21166, and that the city complied with CEQA in proceeding by way of an addendum to the prior environmental impact report because substantial evidence supported the city's finding that the specific plan amendment would not have any reasonably foreseeable environmental consequences beyond the construction of the Super Target store. The court also held that the ordinance constituted "spot zoning," but that it was permissible because the city did not abuse its discretion in finding that its amendment to the specific plan was in the public interest and compatible with the general plans of which it was a part. View "Citizens Coalition Los Angeles v. City of Los Angeles" on Justia Law