California Native Plant Society v. County of Los Angeles

In an unpublished decision addressing a greenhouse gas analysis under the California Environmental Quality Act that paralleled the analysis addressed by the California Supreme Court’s 2015 decision in Center for Biological Diversity v. Department of Fish & Wildlife, the California Court of Appeal found, as the Supreme Court had found, that the finding that the project at issue would not have significant greenhouse gas impacts was not supported by substantial evidence and reasoned discussion. This decision came after the California Supreme Court transferred the petitioners' appeal back to the Court of Appeal for reconsideration in light of Center for Biological Diversity v. Department of Fish & Wildlife.

The California Court of Appeal affirmed a trial court’s dismissal of claims in connection with environmental approvals for a section of Newhall Ranch known as Mission Village. As in Center for Biological Diversity v. Department of Fish & Wildlife and Friends of the Santa Clara River v. County of Los Angeles, the court was not persuaded by claims that it was legally impermissible for the environmental review to compare the project’s emissions with emissions under a business-as-usual scenario. The petitioners indicated that they would ask the California Supreme Court to hear this case.