California Country Club Homes Ass'n, Inc. v. City of Los Angeles

In this case we are asked to interpret recent amendments to the Subdivision Map Act. (Gov. Code, § 66410 et seq.) In 1985 the Legislature amended section 66452.6, subdivision (a) to grant automatic 36-month extensions to file final maps provided a developer, who is required as a condition of approval of a tentative map to spend large sums of money on off site improvements, files a phased final map before the tentative map would otherwise expire. That amendment also provided mandatory extensions could not extend the life of a tentative map beyond 10 years from its initial approval date. In 1992 the Legislature amended subdivision (e) of this section to clarify discretionary extensions of time of up to three years could extend the life of a tentative map beyond the time otherwise provided by the mandatory extension provisions of subdivision (a).

When the City of Los Angeles acknowledged Twentieth Century Fox Studio was entitled to a mandatory extension to file a final map on a tract located in Century City which had the effect of extending the overall life of the tentative map beyond 10 years, a homeowner and several homeowner associations challenged the validity of the…