(Download) "Western States Petroleum Assn. V. Superior Court" by Supreme Court Of California ~ Book PDF Kindle ePub Free
eBook details
- Title: Western States Petroleum Assn. V. Superior Court
- Author : Supreme Court Of California
- Release Date : January 16, 1995
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 81 KB
Description
We granted review to determine whether evidence not contained in the administrative record is admissible in a traditional mandamus action to show that a quasi-legislative administrative decision was a "prejudicial abuse of discretion" within the meaning of Public Resources Code section 21168.5, a provision of the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.), either because the agency "has not proceeded in a manner required by law" or because the decision was not supported by "substantial evidence." We conclude that the substantial evidence standard of review prescribed by this statute is analogous to the substantial evidence standard of review applied by appellate courts to evaluate the findings of fact made in trial courts. Accordingly, just as appellate courts generally may not consider evidence not contained in the trial record when reviewing such findings, courts generally may not consider evidence not contained in the administrative record when reviewing the substantiality of the evidence supporting a quasi-legislative administrative decision under Public Resources Code section 21168.5. We also conclude that extra-record evidence is generally not admissible to show that an agency "has not proceeded in a manner required by law" in making a quasi-legislative decision. Such evidence is generally not admissible to challenge quasi-legislative decisions on non-CEQA grounds, and we see no reason to apply a different rule in CEQA cases.