Committee for Green Foothills v. Santa Clara County Board of Supervisors

Summary

The California Supreme Court held that filing a valid notice of determination under CEQA triggers a 30-day statute of limitations for all CEQA challenges to the decision announced in the notice, regardless of the alleged violation. The court concluded that the Committee for Green Foothills' challenge to Santa Clara County's approval of a trails agreement was time-barred because it was filed 171 days after the revised notice of determination. The court reversed the Court of Appeal's judgment.

Holdings

1. When a valid notice of determination has been filed, any CEQA challenge to the decision announced in that notice must be brought within 30 days, regardless of the nature of the alleged CEQA violation. The plaintiff may not invoke the 180-day period in Public Resources Code section 21167, subdivision (a) merely by alleging that the agency approved the activity without conducting environmental review.
2. The revised notice of determination was in substantial compliance with CEQA's notice requirements and triggered the 30-day limitations period.
3. The Trails Agreement was a subsequent activity within the scope of existing program environmental impact reports, and no new environmental document was required on the facts presented.

Questions Presented

1. Whether filing a notice of determination triggers CEQA's 30-day statute of limitations for all challenges to the decision announced in the notice, even when the plaintiff alleges that the agency approved the activity without conducting environmental review.
2. Whether the County's revised notice of determination was materially defective and therefore incapable of triggering the 30-day limitations period.
3. Whether the Trails Agreement, as a subsequent activity within the scope of existing program environmental impact reports, required a new environmental document.

Disposition

reversed_and_remanded