Citizens for Responsible Equitable Environmental Development v. City of San Diego

A citizens’ group filed a lawsuit challenging San Diego’s certification of an addendum to a 1994 final environmental impact report for a proposed residential development.  Among other things, the group alleged that the city did not take into account new information concerning the effect of greenhouse gases on the climate, and that a supplemental environmental impact report under the California Environmental Quality Act (CEQA) was required.  The trial court dismissed the lawsuit for failure to exhaust administrative remedies.  On appeal, a state appellate court affirmed, holding that the group failed to raise this issue to the city and thus it was not preserved for appeal.