City of Santa Ana v. City of Garden Grove

The City of Santa Ana appeals from an order denying its petition for administrative mandamus seeking review and annulment of a resolution of the City Council of the City of Garden Grove amending its general plan by redesignating a parcel of land on which the boundaries of the City of Santa Ana abut from low density residential to industrial. The thrust of the petition was that the City Council of Garden Grove abused its discretion under the California Environmental Quality Act (CEQA; Pub. Resources Code, § 21000 et seq.) in adopting a negative declaration instead of preparing an environmental impact report (EIR) before taking the challenged action. The trial court denied the petition on the sole ground that CEQA does not apply to an amendment to a general plan.

The pertinent facts may be briefly stated. Subject parcel consists of 54.27 acres in the City of Garden Grove located at the northwest corner of the intersection of Euclid Street and Hazard Avenue. The boundaries of Santa Ana lie directly south of Hazard Avenue and east of Euclid Street. Garden Grove initiated proceedings to amend its general plan by changing the land use designation of the parcel from low density…