By Cori Badgley
Generally, a lawsuit challenging an agency’s decision or environmental review must be brought within 30, 60 or 90 days, depending on the applicable statute of limitations. Often, an agency’s decision involves powers granted under different statutes, which can lead to conflicting statutes of limitations. In Strother v. California Coastal Commission (2009) 173 Cal.App.4th 873, the Court of Appeal for the Fourth Appellate District addressed such a conflict in a challenge to the granting of a coastal development permit. The conflict arose between the statute of limitations under the California Coastal Act (Pub. Resources Code § 30801) and the California Environmental Quality Act (“CEQA”) (Pub. Resources Code § 21080.5). The court held that as long as the challenges related to CEQA, CEQA’s statute of limitations applied.