Federation of Hillside & Canyon Assns. v. City of Los Angeles

In Federation of Hillside & Canyon Assns. v. City of Los Angeles (2004) 126 Cal.App.4th 1180, a city certified an EIR concerning amendments to the city's general plan, and approved the amended general plan. (126 Cal. App. 4th at pp. 1188-1190.) After a public interest group sought administrative mandamus regarding the EIR and amendments to the general plan, the trial court rejected the challenges to the EIR, but ultimately issued a writ directing the city to correct the amendments. (Id. at pp. 1190-1191.) When the city did so, the group again sought administrative mandamus, and asserted new challenges to the EIR. (Id. at pp. 1193, 1204.) The appellate court held that the doctrine of res judicata barred their cause of action regarding the EIR. (Id. at pp. 1202-1205.) In so concluding, the court noted that an "injury," for purposes of determining a primary right, "is defined in part by reference to the set of facts, or transaction, from which the injury arose." (Id. at p. 1203.) As the group challenged the same EIR and the material facts had not changed, the court determined that the second action involved the same primary right. (Id. at p. 1204.)