Pacific Palisades Bowl Mobile Estates, LLC v. City of Los Angeles

The California Legislature enacted a statute—Government Code [1] section 66427.5—that facilitates the conversion of mobilehome parks to resident ownership by limiting a local authority's traditional power to regulate development within the local authority's territory when the proposed development is the conversion of a mobilehome park. That statute imposes certain specific requirements on the subdivider seeking the conversion (aimed at preventing the displacement of current residents, particularly those with lower incomes), and provides that the scope of the hearing at which the local authority may approve, conditionally approve, or deny the tentative map "shall be limited to the issue of compliance" with the specific requirements set forth in the statute. (§ 66427.5, subd. (e).)

But the Legislature also enacted a statute—section 65590, part of the Mello Act—that "establishes minimum requirements for housing within the coastal zone for persons and families of low or moderate income" (§ 65590, subd. (k)) and requires local governments to deny the conversion of mobilehome parks within the coastal zone unless certain requirements have been met (§ 65590, subd. (b)).…