Carrancho v. California Air Resources Board

In Carrancho v. California Air Resources Board (2003) 111 Cal.App.4th 1255, rice grower plaintiffs petitioned for a writ of mandate on allegations that a diversion plan and progress report prepared by responsible state agencies and required by the Legislature failed to comply with the enabling statute. They lost. On appeal, the growers asserted that the trial court should have exercised its independent judgment in reviewing the plan and report. Concluding that the actions of the responsible agencies in preparing the plan and report were quasi-legislative in nature, the Carrancho court undertook a deferential review to determine whether these actions were arbitrary or capricious. (Carrancho, supra, 111 Cal.App.4th at pp. 1259, 1265-1267, 1272-1274, 1278-1279.)