Coalition for a Sustainable Future in Yucaipa v. City of Yucaipa
198 Cal. App. 4th 939
| Cal. Ct. App. | 2011Background
- Coalition appeals a denial of a writ of mandate challenging a City of Yucaipa shopping center approved with Target on Palmer land.
- The principal ground is noncompliance with affordable housing requirements; additional challenges include greenhouse gas, urban decay, and traffic considerations.
- City and Target moved to dismiss the appeal as moot after respondents’ brief, and the court initially denied but allowed reconsideration; the case was ultimately deemed moot.
- Events after the filing of the appeal included Target and Palmer abandoning the project due to a contract dispute and City rescinding the approvals, amendments, and EIR certification.
- The court adopts the Paul v. Milk Depots procedural disposition to vacate the final judgment and dismiss the underlying action as moot, returning jurisdiction to the superior court.
- Disposition: reversal of the judgment as moot and dismissal of the underlying action; each party bears its own appellate costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness disposition appropriate under Paul | Coalition argues mootness justified Paul disposition. | City/Target argue mootness not properly rendered; relief outstanding. | Yes; Paul disposition applied. |
| Effect on merits and finality | Merits not fully litigated; mootness invalidates final judgment. | Dismissal would imply approval of a moot judgment. | Judgment reversed to dismiss underlying action as moot. |
| Res judicata/collateral estoppel implications | Moot judgment could have res judicata effect. | Reversal vacates judgment, preventing preclusion. | Reversal vacates judgment; no res judicata effect. |
| Scope of Paul narrative with Lee and Bottlers distinctions | Paul framework controls moot disposition. | Lee and Bottlers distinguishable; not controlling here. | Paul framework controls; distinctions not dispositive. |
| Nature of the underlying project’s disappearance | Basis for judgment vanished with project abandonment. | Rescissions and abandonment moot the case. | Basis disappeared; mootness supported. |
Key Cases Cited
- Paul v. Milk Depots, Inc., 62 Cal.2d 129 (Cal. 1964) (disposition in moot appeals via reversal to dismiss underlying action; expands mootness remedy)
- Lee v. Gates, 141 Cal.App.3d 989 (Cal. App. 1983) (moot injunctions where changed circumstances make relief unnecessary)
- National Assn. of Wine Bottlers v. Paul, 268 Cal.App.2d 741 (Cal. App. 1969) (discussion of Paul disposition considerations in similar context)
- Bottlers v. Paul, 268 Cal.App.2d 741 (Cal. App. 1969) (application of Paul disposition to avoid mootness implications)
- Lyons v. Security Pacific Nat. Bank, 40 Cal.App.4th 1001 (Cal. App. 1995) (finality considerations in judgments rendered moot on appeal)
- Chamberlin v. City of Palo Alto, 186 Cal.App.3d 181 (Cal. App. 1986) (issues of finality and preclusion in moot judgments)
- Saller v. Crown Cork & Seal Co., Inc., 187 Cal.App.4th 1220 (Cal. App. 2010) (unqualified reversal vacates judgment for mootness purposes)