Placerville Historic Preservation League v. Judicial Council of CA, A149501

The Judicial Council prepared an EIR to relocate El Dorado County court operations from a historic downtown Main Street Courthouse and a county complex into a new courthouse on the city outskirts. The Main Street Courthouse would be retired as a courthouse but is a CEQA-designated historical resource.
The draft EIR addressed historic preservation and required any reuse to follow the Secretary of the Interior’s Standards to avoid a substantial adverse change.
The draft EIR considered but concluded urban decay in downtown Placerville was not a reasonably foreseeable indirect impact of relocation, relying on: (a) city and county commitments to find reuses for the courthouse; and (b) existence of other businesses not dependent on courthouse traffic.
Local merchants and residents submitted comments asserting the courthouse drives significant downtown commerce (citing informal polls, estimated daily visitors, and recent business closures), urging assessment of economic impacts and annex/alternatives.
The Judicial Council certified the Final EIR; the Placerville Historic Preservation League petitioned for a writ of mandate alleging the EIR failed to treat the risk of urban decay as a significant environmental effect.
The trial court denied the petition; the Court of Appeal affirmed, holding substantial evidence supported the Judicial Council’s conclusion that urban decay was not reasonably foreseeable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the EIR should have treated relocation of court functions as causing "urban decay" (a significant environmental effect)	League: courthouse withdrawal will cause severe downtown economic decline and physical deterioration; commenters’ surveys and business closures show likely urban decay	Judicial Council: no substantial evidence of physical deterioration; downtown has independent businesses; city/county commitment and mitigation (historic-standards reuse) make urban decay unlikely	Court: Affirmed — substantial evidence supports conclusion urban decay is not reasonably foreseeable; no requirement for additional economic study or to adopt reuse as mitigation

Friends of the Eel River v. North Coast Railroad Authority, 3 Cal.5th 677 (2017) (EIR purpose and CEQA overview)
Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal.3d 376 (1988) (EIR as informational document)
Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova, 40 Cal.4th 412 (2007) (standard of review; substantial evidence deference)
Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal.App.4th 1184 (2004) (when economic effects may require EIR analysis for urban decay)
Joshua Tree Downtown Business Alliance v. County of San Bernardino, 1 Cal.App.5th 677 (2016) (definition and parameters of "urban decay")