Bridges v. Mt. San Jacinto Community College Dist., E065213M

Background

Mt. San Jacinto Community College District negotiated and in June 2014 executed a purchase agreement to buy ~80 acres in Wildomar from the Riverside County Regional Park & Open‑Space District; the agreement conditions opening escrow and closing on CEQA compliance.
The college previously circulated a 2004–2006 CEQA NOP/initial study describing a potential Southwest Campus, and a 2010 facilities master plan PowerPoint discussed a hypothetical Wildomar campus, but no detailed development plan or board vote approving a project was in the record.
The college had paused EIR work during earlier litigation (Ste. Marie); by the May 2014 board meeting it indicated it was preparing an EIR and would complete it before opening escrow.
Appellants (local residents) filed a CEQA petition the day voters approved the college’s bond measure, seeking to void the purchase agreement for failure to prepare an EIR before execution and to compel adoption of local CEQA implementing guidelines.
The trial court dismissed the petition; the Court of Appeal affirmed, concluding appellants failed to exhaust administrative remedies and, on the merits, the purchase agreement did not trigger a pre‑signing EIR and the college properly "utilized" existing CEQA Guidelines so did not need to adopt its own local guidelines.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies	Appellants excused because they lacked notice of the May 8, 2014 board meeting approving the purchase agreement	Board meeting was publicly noticed; appellants had opportunity to object and did not; exhaustion is required under §21177	Court presumes agency duties regularly performed; no evidence of defective notice; exhaustion required and not shown, so petition barred
Timing of EIR duty (must EIR be completed before signing purchase agreement?)	College should have prepared an EIR before executing the purchase agreement	The agreement conditions purchase/escrow on CEQA compliance; CEQA permits contingent land acquisition where use is conditioned on CEQA review	Court: EIR not required before signing a land acquisition agreement conditioned on CEQA compliance; execution did not trigger EIR duty
Whether the purchase agreement is a CEQA “project”	Purchase agreement is a project that may cause environmental effects and therefore required an EIR before approval	Agreement lacks specific development commitments or plans; no definite course of action was adopted	Court: agreement is not a CEQA project because no concrete development plans or commitments existed, so CEQA review would have been premature
Local implementing guidelines (§21082)	College violated §21082 by not formally adopting local CEQA implementing guidelines	College "utilizes" CEQA Guidelines (and county/Chancellor’s Office guidelines), which §21082 allows in lieu of adopting its own	Court: §21082 permits a school district to utilize another agency’s guidelines; formal resolution not required; claim fails

Key Cases Cited

Ste. Marie v. Riverside County Regional Park & Open‑Space Dist., 46 Cal.4th 282 (2009) (prior litigation determining park‑dedication issue that affected timing of sale)
Tomlinson v. County of Alameda, 54 Cal.4th 281 (2012) (exhaustion doctrine and purposes of CEQA review)
Save Tara v. City of West Hollywood, 45 Cal.4th 116 (2008) (limits on agency commitment and CEQA land‑acquisition exception)
Laurel Heights Improvement Assn. v. Regents of Univ. of Cal., 47 Cal.3d 376 (1988) (EIR must inform decisionmakers before project approval; premature review is not useful)
Stand Tall on Principles v. Shasta Union High Sch. Dist., 235 Cal.App.3d 772 (1991) (conditional site selection contingent on CEQA compliance does not necessarily trigger EIR)
Friends of the Sierra Railroad v. Tuolumne Park & Recreation Dist., 147 Cal.App.4th 643 (2007) (land transfer not a CEQA project absent concrete development plans)