California Court of Appeal

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Citizens for Environmental Responsibility v. State of California ex rel. 14th District Agricultural Association, C070836

The trial court properly denied plaintiffs' petition for writ of mandate and complaint alleging that defendants violated the California Environmental Quality Act (CEQA) by approving a notice of exemption (NOE) from environmental review for a rodeo held at the Santa Cruz County Fairground in 2011, where: 1) the Manure Management Program was not a mitigation measure precluding the categorical exemption; 2) the Class 23 categorical exemption applies to the proposed rodeo project; and 3) there were no "unusual circumstances" taking this rodeo project out of the categorical exemption for "normal operations" of the Fairground.

Appellate Information

  • Decided 03/26/2014
  • Published 03/26/2014




  • California Court of Appeal


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