La Fe, Inc. v. County of Los Angeles

I. Introduction

This case presents the question whether a lot line adjustment constitutes “development” that falls within the permit jurisdiction of the California Coastal Commission (the commission) under the California Coastal Act of 1976 (Pub. Resources Code, § 30000 et seq.) (the act). The Supreme Court noted this issue, but did not decide it, in Landgate, Inc. v. California Coastal Com. (1998) 17 Cal.4th 1006, 1024-1025 [ 73 Cal.Rptr.2d 841 , 953 P.2d 1188 ]. Plaintiffs, La Fe, Inc., Robert Rein, Susan Brown, David Brown, Larry Goodwin, Thomas Hudson, and Deborah Hudson, appeal from a judgment denying their petition for writs of mandate and related relief against defendants, the County of Los Angeles (county), and the commission. Section 30106 provides that “development” means “change in the density or intensity of use of land, including, but not limited to, subdivision . . . , and any other division of land, including lot splits . . .” (Italics added.) Given this broad language selected by the Legislature, we conclude the lot line adjustments in this case constitute “development” within the meaning of the act. Accordingly, we affirm the judgment.

II. The Coastal…