In Nasha v. City of Los Angeles (2004) 125 Cal.App.4th 470, a city planning director approved a five-residence development project in the Santa Monica Mountains, subject to conditions. There was a properly authorized appeal by a neighbor and a conservancy to the planning commission. (Nasha, supra, 125 Cal.App.4th at p. 475.) Prior to the hearing by the commission, however, one of the planning commission members wrote an unsigned article in a local residents association's newsletter advocating "a position against the project" because he perceived it to be a threat to wildlife migration patterns. (Id. at p. 484.) He also spoke against the project at a neighborhood association meeting. While the commission member acknowledged, at the planning commission meeting, that he was the author of the unsigned article, he did not disclose that it was not "merely informational," but rather "advocated a position against the project." (Id. at p. 477.) And at the meeting, the commission member was the one to bring the motion to grant the appeal from the director's decision, which was then carried on a three-to-one vote. (Id. at pp. 477-478.) The developer subsequently sought a writ of mandate to overturn the planning commission decision, but the trial court denied it on the ground the developer should have known about the member's authorship of the article. The Court of Appeal reversed, concluding the planning commission's decision was "tainted by bias and must be vacated," with directions to the trial court to issue an order to the planning commission to reconsider the appeal before "an impartial panel." (Id. at pp. 485-486.) The Nasha court held the developer had established "an unacceptable probability of actual bias" on the commission member's part. (125 Cal.App.4th at p. 482.)