Endangered Habitats League, Inc. v. County of Orange

In Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, the court explained that "we review decisions regarding consistency with a general plan under the arbitrary and capricious standard. These are quasi-legislative acts reviewed by ordinary mandamus, and the inquiry is whether the decision is arbitrary, capricious, entirely lacking in evidentiary support, unlawful, or procedurally unfair. Under this standard, we defer to an agency's factual finding of consistency unless no reasonable person could have reached the same conclusion on the evidence before it." (Id. at p. 782.) In a footnote, however, the court also explained as follows: "We note some cases review consistency with a general plan under the abuse of discretion standard applicable to administrative mandamus, inquiring if the agency has proceeded as required by law and the decision is supported by substantial evidence. Under the substantial evidence prong, a common formulation asks if a reasonable person could have reached the same conclusion on the evidence. Since this is the same test used under the arbitrary and capricious standard for factual findings, for purposes of this case we see no inconsistency." (Id. at p. 782, fn. 3.)