Sierra Club v. City of Hayward

In Sierra Club v. City of Hayward (1981) 28 Cal.3d 840, the California Supreme Court flatly refused to infer necessary administrative findings in a case where the record contained no evidence that a city council had actually addressed the issue in question: "In this case we do not know, and cannot ascertain from a review of the evidence, whether or not the city council made the required findings. ... Nor is the presence in the record of scattered and contradictory evidence relating to the issue sufficient to satisfy us that the council made a deliberate determination of the issue. Indeed, even the existence of substantial evidence to support a necessary determination would not compel a conclusion that the determination was in fact made. The substantial evidence test compels courts only to sustain existing findings supported by such evidence, not to hypothesize new findings. "