Santa Clarita — CEQA Statute and Guidelines (2025

The County of Los Angeles approved a vesting subdivision map including 37 home lots, public facilities, and an oak tree removal permit on a rural lot on the basis of a mitigated negative declaration (MND). Santa Clarita Organization for Planning the Environment (SCOPE) sued the County of Los

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Association of Environmental Professionals 2025

Summary of Key 2024 CEQA Court Cases

Angeles, alleging that the MND was inadequate and that the subdivision did not comply with Los Angeles County codes. The trial court dismissed the lawsuit, holding that SCOPE had failed to serve a summons on the County of Los Angeles within 90 days of approval of the subdivision map as required by Government Code Section 66499.37 (under the Subdivision Map Act).

On appeal, SCOPE argued that Section 66499.37 did not apply to the CEQA challenge. The Court of Appeal reviewed the application of Section 66499.37 in detail and concluded that Section 66499.37 does not apply to challenges to the “procedural violations of CEQA (for example, lack of adequate notice of the mitigated negative declaration) and the County’s failure to analyze and disclose the Project’s environmental impacts, all of which are unique to CEQA and could not have been brought under the [Subdivision Map Act].” The Court reversed the trial court on this point, allowing the basic challenge to the MND to proceed on remand to the trial court.

However, to the extent that SCOPE challenged the reasonableness of the mitigation measures as conditions of approval of the vesting subdivision map, the Court concluded that “the limitations period under [s]ection 66499.37 applies.” Therefore, SCOPE had forgone its ability to make this challenge by failing to file within the 90-day period.