California Case Summaries

Environmental Law

Primary practice area

5th District Court of Appeal, Administrative Law, Environmental Law, Litigation

San Joaquin Facilities Management, Inc. v. Department of Conservation — New Water Injection Wells Are Not Exempt from CEQA Review, and the Writ Is Reversed

automatic / October 15, 2026

The Fifth District reversed a writ that had compelled CalGEM to treat a plan for up to 12 new water injection wells as exempt from CEQA, holding that the pre-CEQA private project guideline is invalid and, in any event, inapplicable, and that the class 1 and class 4 categorical exemptions did not apply.

Ninth Circuit Court of Appeals, Administrative Law, Constitutional Law, Environmental Law

Rinnai America Corp. v. South Coast Air Quality Management District — Federal Energy Law Does Not Block California’s Zero-Emission Appliance Rules

automatic / July 2, 2026

The Ninth Circuit ruled 2-1 that the federal Energy Policy and Conservation Act (EPCA) does not preempt SCAQMD's Rule 1146.2, which phases out gas-fired water heaters and boilers across Southern California to achieve compliance with federal ozone standards — dealing a major setback to appliance manufacturers challenging the ban.

Ninth Circuit Court of Appeals, Administrative Law, Environmental Law

Rinnai America Corp. v. South Coast Air Quality Management District — Federal Energy Law Does Not Preempt SCAQMD’s Zero-NOx Gas Appliance Rule

automatic / July 2, 2026

The Ninth Circuit, 2-1, holds that the Energy Policy and Conservation Act (EPCA) does not preempt the South Coast Air Quality Management District's Rule 1146.2, which phases in zero-NOx emission standards for gas water heaters and boilers to bring the Los Angeles Basin into compliance with federal ozone standards under the Clean Air Act.

3rd District Court of Appeal, Administrative Law, Environmental Law, Tax (non-estate)

Garst v. Tehama County Flood Control District — Countywide Groundwater Registration Charge Is an Unconstitutional Tax

automatic / June 29, 2026

The Third District struck down a Tehama County groundwater district's per-acre annual charge as an unconstitutional tax rather than a valid regulatory fee, ruling that Proposition 26 bars a fee imposed on parcels with no groundwater wells for a well-registration program that provides no direct service to those parcels.

4th District Court of Appeal, Administrative Law, Environmental Law, Litigation

Protect Our Communities Foundation v. City of San Diego — SDG&E Franchise Upheld; CEQA, Prop. 26, and Charter Bidding Challenges Rejected

automatic / June 26, 2026

The Fourth District upholds the City of San Diego's 20-year gas and electric franchise agreements with SDG&E, rejecting challenges under CEQA, Proposition 26, and the City Charter's competitive bidding rules, while striking a supermajority termination clause as inconsistent with the Charter.

California Supreme Court, Administrative Law, Environmental Law

Sunflower Alliance v. Department of Conservation — California Supreme Court Clarifies CEQA Class 1 Exemption Turns on Change in Use, Not Environmental Risk

automatic / June 25, 2026

The California Supreme Court holds that CEQA's class 1 categorical exemption — covering 'negligible or no expansion of existing or former use' — asks whether the change in use is negligible, not whether the project poses negligible environmental risk.

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