The Second Appellate District affirmed a judgment issuing a peremptory writ of mandate. The court held that the City of Manhattan Beach was required to prepare an environmental impact report under the California Environmental Quality Act prior to adoption of an ordinance banning certain retailers, including grocery stores, from providing plastic bags to consumers.

The City of Manhattan Beach adopted Ordinance 2115, which prohibited certain retailers, including grocery stores, from distributing plastic bags to consumers at the point of sale. The city’s goal, as reflected in the ordinance, was to protect the marine environment and marine life from the effects of pollution from plastic bag debris.