Award Of Private Attorney General Attorney Fees Reversed.

In the trial court in a matter concerning a homeowner’s request to build an addition, which had been denied in part by the Coastal Commission, the superior court issued a writ of mandate stating that the Coastal Commission’s findings with respect to a bluff edge were not supported by substantial evidence. Thereafter the trial court awarded attorney fees to the homeowner pursuant to the private attorney general fees permitted under Code of Civil Procedure section 1021.5. The appellate court reversed, stating: “The issuance of a peremptory writ of mandate did not confer a substantial benefit on either the general public or a large number of persons.  Moreover, the financial burden of the litigation was not out of proportion to Norberg’s individual stake in the matter.” (Norberg v. California Coastal Commission (Cal. App. Fourth Dist., Div. 3; November 15, 2013) 221 Cal.App.4th 535.)