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Laurel Way Appellate Decision

Posted: Wed Aug 30, 2017 8:16 am
by Ian Wilson
This is why I get up in the morning.

Our firm has been involved in this project for a number of years. I got involved a short time ago.

This was a case that relied heavily on Gardner v. County of Sonoma (2003) 29 Cal.4th 990, Abernathy Valley, Inc. v. County of Solano (2009) 173 Cal.App.4th 42, Home Ranch, Inc. v. County of Sonoma (2008) 165 Cal.App.4th 543 and a few others.

The map was recorded in 1926. I’ve attached it for reference. The lots in question are on sheet 4. Lots 12, 13, and 14 have already been combined into one lots.

I’ve also attached a Google Earth Image. The cul-ds-sac is at 37°28’00”N / 122°15’28”W.

Our clients are the property owners who want to build homes.

This has been going on for years. Initially, the project was a Planned Development Permit (PDP) to build out the road and utilities along the end of Laurel Way. Redwood City approved the plans after going through the plan review and EIR process.

The local home owners got together as Save Laurel Way to oppose the project. It went to court. The trial judge enjoined the project based on the fact that the subdivision map did not receive the review required under the Subdivision Map Act (SMA) and the lots were not legal lots.

Even though the Appellate Court had 90 days to come back with their decision, they only took a month to overturn the decision.

The trial court reasoned that “the issue is not whether the 1926 subdivision map here complied with the law as of 1926, but whether it complies with the law now or otherwise fits squarely within the grandfather clause under the present language.” Relying on Abernathy and Hays, the court concluded there was no showing in the record that any applicable “design and improvement” laws existed when the 1926 Map was filed. Thus, it did not appear that the parcels in the Project would fall within the SMA’s grandfather provision. However, the trial court did not make an ultimate finding as to whether the lots are illegal. Rather, it found that the city abused its discretion because it expressly found all 16 Project lots were legally created without having considered their status under the SMA. While the court’s reasoning is not inconsistent with the pertinent authorities, its ultimate conclusion is flawed.

The story is not over.

Future instalments to come…

Re: Laurel Way Appellate Decision

Posted: Sat Sep 09, 2017 10:52 am
by Dave Karoly, PLS
Interesting.

So they can build the street and utilities but the issue of whether the lots are legal is not ripe yet.

Are the lots owned by different entities?

Re: Laurel Way Appellate Decision

Posted: Sat Sep 09, 2017 12:40 pm
by Ian Wilson
So it would seem, David. Construction of utilities does not require legal lots.

The lots are currently all under different owners and have been for this entire millenium...

Re: Laurel Way Appellate Decision

Posted: Mon Sep 11, 2017 6:55 pm
by btaylor
I may be missing something, but doesn't the finding that the "lots are not legal" per se affect any older subdivision when there was "no showing in the record that any applicable 'design and improvement' laws existed"? Seems like a crazy, short-sighted ruling.

Re: Laurel Way Appellate Decision

Posted: Tue Sep 12, 2017 11:00 am
by Dave Karoly, PLS
I think the deal is if the Lots were conveyed separately using the Plat designation (e.g. Lot 12 of Steepness Acres) prior to the next iteration of the SMA then they are legal lots.

I'm not an expert, though.