FRIENDS OF EAST WILLITS VALLEY v. County of Mendocino

This case presents an apparent conflict between a Native American tribe’s desire to build low-income homes for its members and Willits Valley residents’ efforts to preserve open space for agricultural uses. The Mendocino County Board of Supervisors voted to grant the Sherwood Valley Rancheria’s request for cancellation of Williamson Act agricultural use restrictions on land the tribe sought to develop. It issued a negative declaration that the tribe’s limited project would have no significant environmental impacts. The trial court issued a peremptory writ of mandate directing Mendocino County to set aside its approvals. Because we conclude that the decision to adopt a negative declaration was permitted as a matter of law and the decision to cancel the agricultural use restrictions was supported by substantial evidence, we reverse.

Background

The Sherwood Valley Ranchería (Tribe) consists of approximately 400 members of the Porno Indian tribe. The Willits Valley is its aboriginal territory. Its existing land is insufficient to provide homes for the current members of the Tribe; approximately 40 families are now on a waiting list for adequate housing. The Tribe has…