Santa Rita Union School District v. City of Salinas
Annotate this Case
The Draft Environmental Impact Report (EIR) prepared (California Environmental Quality Act (CEQA) Pub. Resources Code, 21000) for Santa Rita’s West Area Specific Plan did not discuss or analyze any potential off-site impacts flowing from an assumption that contemplated new schools would never be built. The school districts contended that they would never receive sufficient funding for the new facilities, and would have to accommodate new students from Specific Plan developments at existing school sites or by other means. The Project identified locations for new schools and the EIR addressed anticipated off-site impacts of development at those sites. The City imposed developer impact fees for the Project under Education Code 17620, deemed complete mitigation under CEQA. The City maintained that information relayed by the Districts amounted to no more than speculation, not requiring further review. After the City approved the Project, the Districts filed suit.
The court of appeal concluded that the Final EIR complied with CEQA and properly assumed that the contemplated new schools would be built as part of the Specific Plan and Project. The City was not required to analyze any potentially significant off-site impacts of ill-defined, generalized, and speculative alternatives to new-school construction offered by the District The Districts’ expressed concerns about a perennial lack of sufficient funding without providing more detailed information or identifying a specific alternative plan to address this possibility—for which they, not the City, would be responsible—amounted to speculation.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.