In Robinson v. Superior Court (2023) 88 Cal.App.5th 1144, the Fifth District Court of Appeal held that Southern California Edison (SCE), as an investor-owned public utility, was not required to comply with CEQA in an eminent domain action because SCE was neither a “public agency” under CEQA nor did SCE need approval from a public agency to condemn private property. In separate holdings, not discussed further in this summary, the Court also found that the trial court failed to make explicit findings on the record that SCE satisfied the conditions precedent to the exercise of power of eminent domain set out in Code of Civil Procedure section 1240.030, and, as a result, the Court determined there was prejudicial error as portions of SCE’s claims were not supported by substantial evidence. The Court issued a peremptory writ ordering the trial court to vacate its order granting SCE’s motion for prejudgment possession and to conduct further proceedings on the motion.