Howard

This appeal arises out of the dismissal of plaintiffs Steve Howard and Megan McQuaide’s (together, plaintiffs) complaint against the County of San Diego (the County), wherein they alleged the County inversely condemned their property when it allegedly refused to process plans for a metal bam on their property in Campo, California, because its location was in the footprint of a potential road. The County brought a motion for judgment on the pleadings, arguing, among other things, plaintiffs failed to exhaust their administrative remedies. The court granted the motion and dismissed the complaint without prejudice. Thereafter, plaintiffs moved to amend the complaint, alleging they had exhausted their administrative remedies because they unsuccessfully sought a remapping of the proposed road. The County opposed the motion, asserting plaintiffs had still failed to exhaust their administrative remedies because they could have sought an amendment to the County’s general plan. The court denied leave to amend and entered judgment in favor of the County.

Plaintiffs appeal asserting (1) that all reasonable administrative remedies have been exhausted and (2) that requiring…