Golden State Environmental Justice Alliance v. City of Los Angeles

The California Court of Appeal ruled that a petitioner failed to exhaust administrative remedies because it had not asserted during administrative proceedings its specific claim that the California Environmental Quality Act (CEQA) review for a 34-story building in Los Angeles did not properly assess the project’s compliance with greenhouse gas emission targets for 2030 and 2050 established by executive orders. The court said the petitioner’s comments on the draft and final environmental impact reports concerning the analysis of greenhouse gas emissions were not sufficient to exhaust administrative remedies. The appellate court therefore affirmed the denial of the mandate petition with regard to greenhouse gas emissions.