Citizens Coal. L. A. v. City of L. A.

A city council passed an ordinance that (1) amended its neighborhood-based "specific plan" to create a new subzone for large commercial development, and (2) placed a half-built Super Target retail store into that new subzone. Two citizens groups attacked the city's ordinance, and the trial court ruled that the city violated *319the California Environmental Quality Act (CEQA) ( Pub. Resources Code, § 21000 et seq. )1 because the city treated the creation of the new subzone as a follow-on to its prior, initial approval of the Target store rather than as a entirely new "project" under CEQA.

This…