Coachella Valley Water District v. Western Allied Properties, Inc.

The California Constitution guarantees the property owner in a condemnation action a jury trial on the question of “just compensation.” (Cal. Const., art. I, § 19.) In this appeal we decide the court’s evidentiary rulings improperly intruded on the jury’s role. We therefore reverse the judgment and remand the case for retrial of the jury phase consistent with the views expressed in this opinion. At the same time we affirm the court’s finding that Coachella Valley Water District complied with the requirements of the California Environmental Quality Act (CEQA). (Pub. Resources Code, § 21000 et seq.)

Factual and Procedural Background

The Coachella Valley Water District (Water District) commenced this eminent domain action against Western Allied Properties, Inc. (Western Allied) and others to acquire land for construction of a flood control channel in the Palm Desert region of Riverside County. The events underlying the action began with a pair of natural disasters. In September 1979 tropical storm Kathleen caused severe flooding in the desert communities of Palm Desert, Rancho Mirage and Indian Wells. Tropical storm Doreen hit three years later. The damage from the two…