Woodland Hills Residents Assn., Inc. v. City Council of Los Angeles

In Woodland Hills Residents Assn., Inc. v. City Council of Los Angeles (1979) 23 Cal.3d 917, the plaintiffs challenged the approval of a proposed subdivision map on several grounds, including that the subdivision was inconsistent with the general plan and that the approval had not contained a specific finding that the subdivision was consistent with the general plan. (Id. at p. 926.) The trial court found in the plaintiffs' favor on the narrow ground that the approval of the subdivision map did not contain a specific finding that the subdivision was consistent with the general plan, and having so concluded, the trial court found it unnecessary to resolve whether the subdivision map was in fact consistent with the general plan. (Id. at pp. 926-927.) The Supreme Court held that "the fact that a plaintiff is able to win his case on a 'preliminary' issue, thereby obviating the adjudication of a theoretically more 'important' right, should not necessarily foreclose the plaintiff from obtaining attorney fees under a statutory provision. When a defendant's action is invalid on a number of grounds, it would be both unfair and contrary to the legislative purpose of Code of Civil Procedure section 1021.5 to deprive a plaintiff of attorney fees simply because the court decides the case in plaintiff's favor on a 'simpler' or less 'important' theory. On the other hand, of course, the fact that a plaintiff prevails on a 'technical' preliminary issue does not necessarily demonstrate that his additional claims have sufficient merit to warrant the conclusion that the action served to vindicate an important right. Under such circumstances, the trial court, utilizing its traditional equitable discretion (now codified in Code Civ. Proc., 1021.5), must realistically assess the litigation and determine, from a practical perspective, whether or not the action served to vindicate an important right so as to justify an attorney fee award under a private attorney general theory." (Woodland Hills, supra, 23 Cal.3d at p. 938.)