City of Goleta v. Superior Court

In June 1999, Oly Chadmar Sandpiper General Partnership (Sandpiper) (plaintiff) bought land to develop residential units in Santa Barbara County (the county). In July 1999, the county’s residents began signing a petition to incorporate the city of Goleta (the city) (defendant) within the county. Sandpiper’s land was included within the city’s boundaries. In November 1999, Sandpiper submitted to the county a tentative subdivision map detailing the planned construction. In November 2001, residents voted to approve the city’s incorporation. In January 2002, the county approved Sandpiper’s tentative map. In February 2002, the city was incorporated. As required by law, the county’s subdivision ordinances became the city’s subdivision ordinances for 120 days. The city made no changes to the ordinances other than substituting the city’s name for the county’s name. The city placed a moratorium on development, but excluded Sandpiper’s development on the ground that the development posed no threat to public health, safety, or welfare. In June 2002, the city chose to readopt the subdivision ordinances. In November 2002, the city received Sandpiper’s final subdivision map, which was consistent with the county-approved tentative map. The city denied the final map’s approval on the ground that the city was unsure the development would promote the health, safety, and welfare of the city. Sandpiper filed an action in California trial court on the ground that the city was required to approve the final map. The trial court returned a verdict in Sandpiper’s favor. The city appealed. The California Court of Appeal reversed. Sandpiper appealed to the California Supreme Court.