Community Youth Athletic Center v. City of National City
220 Cal. App. 4th 1385
Cal. Ct. App.2013Background
- Filed 10/30/13; appellate Court of California Fourth District, Division One; reverse validation and PRA challenges to National City redevelopment amendment.
- City amended 1995 redevelopment plan in 2007 to extend eminent domain powers within a 300-acre area, supported by consultant reports and hearings; opposed by CYAC and Interested Parties.
- CYAC filed reverse validation action seeking declaratory and injunctive relief and damages; Interested Parties joined for similar relief.
- Trial court found CRL violations (no maps, lack of substantial physical blight evidence, missing raw data) and PRA violations; federal due process violations found on a narrow theory; nominal damages awarded.
- Action and consolidated appeals focused on validity of amendment under CRL, PRA disclosures, and related attorney fees; redevelopment agencies had been abolished by 2011 legislation but issues remained live for fees and CRL obligations.
- Court affirms some CRL and PRA relief, reverses federal due process remedy, and remands on attorney fees for reevaluation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| CRL map requirement failed? | CYAC argues RTC lacked required maps and specific quantifiable blight evidence. | City contends substantial compliance and reliance on RTC maps provided later. | Remand for proper application of map and quantifiable-evidence requirements; reverse in part. |
| Substantial evidence of physical blight? | CYAC contends administrative record lacked substantial physical-blight evidence. | City asserts sufficient evidence under updated CRL standards. | Reverse on physical-blight finding; but economic-blight cross-appeal not resolved here. |
| PRA disclosure duties violated? | CYAC claims City failed to produce raw data and properly respond to PRA requests. | City argues reasonable search and custodian communications sufficed. | PRA violations affirmed; remand to determine extent of fees and relief. |
| Federal procedural due process remedy correct? | CYAC asserts denial of timely statutorily required maps violated due process. | City argues CRL procedures suffice; constitutional rights not violated at this stage. | Reversed as to federal due process determination; remand for reconsideration of fee awards. |
Key Cases Cited
- Blue v. City of Los Angeles, Cal.App.4th 1131 (Cal.App.4th 2006) (addressed pre-2006 CRL map/notice standards and Blue's limitations on data disclosure)
- Glendora Redevelopment Project v. City of Glendora, Cal.App.4th 817 (Cal.App.4th 2010) (reinforced need for tangible, quantifiable blight evidence and stricter documentation)
- Riverside County v. City of Murrieta, Cal.App.4th 616 (Cal.App.4th 1998) (definitions of blight and the burden of proof in determining eligibility for redevelopment)
- Cambria Spring Co. v. City of Pico Rivera, Cal.App.3d 1080 (Cal.App.3d 1985) (distinguished eminent domain powers from general planning; finality requirements for damages claims)
- A.C.L.U. of Northern California v. Superior Court, Cal.App.4th 55 (Cal.App.4th 2011) (public records requests; reasonableness of searches and custodians of records)
- California Redevelopment Assn. v. Matosantos, 53 Cal.4th 231 (Cal.4th 2011) (legislative dissolution of redevelopment agencies; mootness of some issues but not fees)