Carpinteria Valley Farms, Ltd. v. County of Santa Barbara

Patrick M. Nesbitt and associated entities Carpintería Valley Farms, Ltd., Yeager Holdings, Inc., and the Patrick M. Nes-bitt Family Trust (collectively, “Nesbitt”) own land in Santa Barbara County, California. Nesbitt wanted to develop the land in a variety of ways, including building a personal residence on it and using part of the property as a private polo field. The County imposed a number of requirements on this planned development which included, inter alia, requiring Nesbitt to apply for a major conditional use permit to play polo on the property and requiring him to accept numerous conditions for issuance of a residential building permit.

After a lengthy period of trying to resolve his differences with the County, Nes-bitt filed the present action under 42 U.S.C. § 1988 . He sued the County of Santa Barbara, its Planning and Development Department, and employees of that Department (collectively, “the County”). He alleged that the County violated his First Amendment rights of free speech and free association by impeding his use and development of the property in retaliation for his participation in protected activities; violated his right to equal protection…