City of Pasadena v. State of California

This appeal arises from a heated public debate about the placement of a parole office in the San Gabriel Valley by the State of California (the State) Department of Corrections (the Department). Responding to complaints from citizens of Alhambra and Monterey Park, the State agreed to relocate a parole office from that area to the Pasadena area. The State selected a site in an existing office building in the Pasadena Civic Center. It determined that its lease of the building was exempt from the requirements of the California Environmental Quality Act (CEQA), Public Resources Code section 21000 et seq. Pasadena brought a petition for writ of mandate to void the lease. The trial court ultimately denied the petition and entered a judgment in favor of the State.

On appeal, Pasadena makes three arguments in support of its position that the State violated CEQA: that the project does not come within the categorical exemption relied upon by the State; that the State’s investigation prior to issuing the exemption was inadequate; and that an exception to the exemption applies because there was a showing that there was a possibility that the lease will have a significant effect on…