Patrick Media Group, Inc. v. California Coastal Commission

The California Coastal Commission (the Commission) appeals from a judgment entered against it and in favor of Patrick Media Group, Inc. (PMG), adjudging PMG entitled to compensation under Business and Professions Code sections 5412 and 5412.6 for the compelled removal of three off-site advertising structures belonging to PMG, as a condition of a coastal development permit issued by the Commission to PMG’s lessor, Solana Beach Innsuites Joint Venture (Solana). The trial court found, on PMG’s motion for summary adjudication of issues, that the Commission was liable for compensation. The parties then stipulated to the amount of damages payable by the Commission if the trial court’s finding of liability were to be affirmed on appeal, and judgment was entered as provided in the stipulation.

We determine that the trial court correctly found the provisions of sections 5412 and 5412.6 applicable to the Commission’s actions respecting PMG’s advertising structures. However, we shall conclude that PMG’s required remedy under those statutes was by way of administrative mandamus, as provided in Public Resources Code section 30801 and Code of Civil Procedure section 1094.5.

As PMG…