Smith v. County of Santa Barbara

Here we hold that the federal preemption doctrine does not prohibit the imposition of county regulations on the construction of a building by a private developer which is intended for lease to a federal agency.

Background

Appellant Carlie Smith seeks damages and the refund of building fees he paid to the County of Santa Barbara (respondent) as the result of respondent’s alleged unlawful interference with his construction project.

In August 1981, appellant received a solicitation for offers from the United States Forest Service (Forest Service) to lease 25,700 square feet of office space in the Goleta area, including space for an automotive and radio shop. The Forest Service was seeking to obtain space for its Los Padres National Forest headquarters which was then scattered among several buildings. The solicitation called for occupancy on October 1, 1982 (the date the Forest Service’s existing lease expired), and contained numerous building specifications.

The solicitation required the successful offeror to sign a United States Government lease, and stated that “[t]he unconditional acceptance of an offer received in response to the Solicitation establishes a valid…