Citizens for Responsible Caltrans Decision. v. Department of TransportationAnnotate this Case
In 2017, the California Department of Transportation (Caltrans) released a final environmental impact report (FEIR) for the construction of two freeway interchange ramps connecting Interstate 5 and State Route 56 (SR 56) (the Project). However, before the public comment period for the FEIR commenced and without issuing a notice of determination (NOD), Caltrans approved the Project a few days later and then filed a notice of exemption (NOE) two weeks later. The NOE stated that the Project was exempt from the California Environmental Quality Act (CEQA) pursuant to Streets and Highways Code section 103,1 which was enacted January 1, 2012. Citizens for a Responsible Caltrans Decision (CRCD) did not become aware of the NOE filing until after the 35-day statute of limitations period for challenging the NOE had run. CRCD filed a petition for writ of mandate and declaratory relief alleging, inter alia, that Caltrans erroneously claimed the Project was exempt from CEQA under section 103 and that Caltrans is equitably estopped from relying on the 35-day statute of limitations for challenging notices of exemption. Caltrans demurred to the petition on the grounds that the causes of action were barred by the applicable statute of limitations and that the Project was exempt from CEQA under section 103. CRCD opposed the demurrer. On appeal, CRCD contended the trial court erred by sustaining Caltrans's demurrer to the petition because: (1) section 103 did not exempt Caltrans from complying with CEQA in its approval of the Project; and (2) the petition alleged facts showing equitable estoppel applies to preclude Caltrans from raising the 35-day statute of limitations. The Court of Appeal agreed that the court erred by sustaining Caltrans's demurrer and therefore reversed the judgment of dismissal.