Tuolumne County Citizens for Responsible Growth, Inc. v. City of Sonora

This appeal concerns a proposal to construct a home improvement center in the City of Sonora. A local citizens’ organization challenged the approval of the project and the adoption of a mitigated negative declaration by alleging violations of the California Environmental Quality Act (CEQA) and local ordinances. The superior court denied the organization’s petition for a writ of mandate.

The organization appealed, arguing that the whole of the action constituting a single CEQA project was segmented when the realignment of an adjacent road was not treated as part of the home improvement center project. This case is similar to Plan for Arcadia, Inc. v. City Council of Arcadia (1974) 42 Cal.App.3d 712 [ 117 Cal.Rptr. 96 ] (Plan for Arcadia), where the court found that the construction of (i) a shopping center, (ii) a parking lot, and (iii) improvements to an adjacent street were all part of a single CEQA project. Following the opinion in that case, we conclude as a matter of law that the construction of the home improvement center and the realignment of the road constitute a single CEQA project. As a result, the combined activity should have been analyzed in the same initial…