Non Blighted Nearby Blighted Property Redevelopment
In Gonzales v. City of Santa Ana, supra, 12 Cal. App. 4th 1335. the issue was the sufficiency of the evidence to support a finding that inclusion of certain nonblighted property was necessary to an area's effective redevelopment. ( Id. at p. 1346.)
Gonzales stated: "As to nonblighted property substantially removed from Bristol Street itself (i.e., not affected by its physical widening), the city has not articulated any concrete reason why that property is 'necessary for the effective redevelopment' of the project area.
The city merely cites certain all-purpose conclusory statements from the consultants' report which might apply to any property anywhere.
With the exception of a brief reference to the 'proposed street widening,' there is no attempt at any specificity; the reasons appear to have emerged from the consultants' word processor without any thought as to why any particular parcel of nonblighted property must be taken by the government to effectively redevelop nearby blighted property.
While the inclusion of nonblighted property within a redevelopment project may be tested on an abuse of discretion standard, . . . there must be some specific connection between the inclusion of nonblighted property and the 'effective redevelopment' of an area.
We would render the statute a dead letter if we allowed generic, 'canned' reasons having no necessary relationship to any given parcel of nonblighted property to serve that purpose." (Id. at pp. 1346-1347.)