City of Redlands v. County of San Bernardino

1. Introduction

The County of San Bernardino (the County) approved amendments that modified its general plan relating to land use regulation of unincorporated territory located within a city’s “sphere of influence.” In connection with the approval of these amendments, the County also adopted a negative declaration under the California Environmental Quality Act (CEQA). The City of Rancho Cucamonga and the City of Redlands filed petitions for writ of mandate on the ground that the County failed to comply with CEQA in adopting the amendments by preparing an environmental impact report (EIR). In particular, Rancho Cucamonga and Redlands argued that the County’s finding of no significant environmental impacts was based on its inaccurate description of the amendments as mere clarifications of existing language in the general plan. The trial court agreed with the cities, granted the petitions, and issued the writ of mandate to set aside the amendments.

In appealing from the trial court’s judgment, the County makes the following arguments: the project description was accurate and, alternatively, even an inaccurate project description would not require the mandatory preparation…