Supporters Alliance etc. v. City of Inglewood CA2/5

CourtCalifornia Court of Appeal
DecidedMarch 19, 2026
DocketB345195
StatusUnpublished

This text of Supporters Alliance etc. v. City of Inglewood CA2/5 (Supporters Alliance etc. v. City of Inglewood CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Supporters Alliance etc. v. City of Inglewood CA2/5, (Cal. Ct. App. 2026).

Opinion

Filed 3/19/26 Supporters Alliance etc. v. City of Inglewood CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

SUPPORTERS ALLIANCE FOR B345195 ENVIRONMENTAL RESPONSIBILITY, (Los Angeles County Super. Ct. No. Plaintiff and Respondent, 23STCP00195)

v.

CITY OF INGLEWOOD et al.,

Defendants and Respondents;

PRAIRIE STATION, LLC,

Real Party in Interest and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Curtis A. Kin, Judge. Affirmed. Allen Matkins Leck Gamble Mallory & Natsis and Patrick E. Breen for Real Party in Interest and Appellant. Lozeau Drury, Michael R. Lozeau, and Richard T. Drury for Plaintiff and Respondent. Supporters Alliance for Environmental Responsibility (SAFER) successfully challenged the City of Inglewood and City Council of the City of Inglewood’s (collectively, the City’s) decision to prepare and adopt a mitigated negative declaration, rather than an environmental impact report, for a new housing development. The trial court subsequently awarded SAFER $165,072.50 in attorney fees pursuant to Code of Civil Procedure section 1021.5 (Section 1021.5). The developer and real party in interest Prairie Station LLC (Prairie) appeals the fee award and we consider (1) whether the trial court gave due weight to factors identified in the Housing Accountability Act (HAA) (Gov. Code,1 § 65589.5) when assessing whether the lawsuit conferred a significant benefit on the public or a large class of persons and (2) whether SAFER’s links to trade unions gave it a financial incentive to litigate that should have foreclosed an award of Section 1021.5 fees.

I. BACKGROUND A. The Project The 5.07-acre project site is located at the intersection of Prairie Avenue and 113th Street in Inglewood. It is bordered by Interstate 105 (I-105) to the southwest, a freeway ramp to the north, Prairie Avenue to the east, and a residential property to the northeast. The site’s zoning designation under the City’s general plan is “Airport Commercial,” meaning there can be no newly constructed residential uses without a general plan amendment

1 Undesignated statutory references that follow are to the Government Code.

2 and a zoning change. The surrounding area is primarily commercial, and nearby uses include a hotel, a grocery store, and a car dealership. Structures previously occupying the site included two commercial buildings, two single-family dwellings, an equipment building, a sign, and an antenna. Most of these have been demolished, leaving a parking lot and a one-story commercial building that is unoccupied. The project was to include three apartment buildings with a total of 440 apartments. Each building was to have one or two floors of parking and six stories of residential units. There was to be open courtyard space on the second floor of each building. There were to be up to 670 parking spaces, including approximately 100 surface parking spaces. Pursuant to a disposition and development agreement between the City and a Prairie affiliate—by which the affiliate would acquire a portion of the site from the City for $3.75 million—40 of the units were to be restricted for occupancy by lower- and moderate-income households.

B. Project Approval The City’s approval of the project involved several discretionary actions implicating the California Environmental Quality Act (CEQA). (Pub. Resources Code, § 21080, subd. (a).) These included approving the disposition and development agreement, amending the general plan, and approving a zoning change. In August 2021, the City made an initial study and mitigated negative declaration (IS/MND) available for public review and comment. In October 2022, the City made a revised IS/MND draft available for public review and comment. The revised IS/MND assessed the Project’s environmental impacts to

3 be “less than significant” as mitigated, which would obviate the need for preparation of an environmental impact report (EIR). (Pub. Resources Code, § 21064.5.) Counsel for SAFER submitted a series of comments during the public comment period on the revised IS/MND. One of these, dated October 27, 2022, asked the City to prepare an EIR because “the IS/MND fails as an informational document” and “there is a fair argument that the Project may have adverse environmental impacts.” (SAFER did not specify any potentially significant environmental impacts in this letter.) On December 19, 2022—after the public comment period closed and one day prior to a public hearing on the disposition and development agreement and IS/MND—counsel for SAFER submitted a letter detailing “significant, unmitigated environmental impacts [that] the [IS/MND] . . . failed to adequately address.” These included “cumulatively significant health risks to future Project residents that would result from exposure to indoor formaldehyde emissions and diesel particulate matter emissions from the immediately adjacent I-105 freeway; insufficient mitigation of health risks to future Project residents and area residents resulting from the Project’s future construction and operational emissions; significant impacts to at least three special-status species living on or near the Project site; and insufficient mitigation of the Project’s significant greenhouse gas and energy impacts.” SAFER’s letter enclosed reports from several independent experts. SAFER’s attorney also reiterated the letter’s concerns at the public hearing held the next day. The administrative record does not show there was any substantive consideration by the City of the concerns SAFER

4 raised. Minutes from the public hearing simply reflect a general response by planning manager Mindala Wilcox (Wilcox), who “stated that several comments were received when the Draft MND was released and made available to the public” and “when the initial MND was prepared, it was based on the current state and the city’s best practices in compliance with CEQA.”2 The City Council voted unanimously to approve the disposition and development agreement and to adopt the revised IS/MND.

C. Litigation After the City’s approval, SAFER petitioned the trial court for a writ of mandate to compel the City to vacate and set aside its project approval and to prepare an EIR. SAFER argued there was substantial evidence of a fair argument that the Project would have significant adverse impacts relating to biological resources, greenhouse gas emissions, and indoor emissions of formaldehyde and the City lacked substantial evidence to conclude emissions of diesel particulate matter would not result in significant cancer risks. The City, joined by Prairie, opposed the petition, arguing SAFER’s petition suffered from several procedural flaws. Among other things, they argued SAFER lacked standing and failed to plead and prove exhaustion of administrative remedies (chiefly by failing to timely submit comments). They did not address the merits of SAFER’s CEQA-related contentions.

2 The administrative record does include emails between Wilcox and others circulating SAFER’s December 2022 letter without substantive comments.

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Bluebook (online)
Supporters Alliance etc. v. City of Inglewood CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/supporters-alliance-etc-v-city-of-inglewood-ca25-calctapp-2026.