Twain Harte Homeowners v. County of Tuolumne

California’s Planning and Zoning Law § 65000 required that the board of supervisors of each county adopt a general plan, or comprehensive plan, for development of county land. The general plan had to comprise nine elements, including a land-use element. The land-use element needed to include a statement of standards for population density and building intensity. Accordingly, the County of Tuolumne (defendant) adopted the Tuolumne County General Plan (the plan). The plan provided specific population densities for only urban-residential uses, which were expressed in terms of maximum dwelling units per acre. For residential/agricultural uses and resource lands, the plan stated densities only in terms of minimum lot sizes. With respect to all other areas, such as areas designated for commercial, industrial, and public/institutional/school uses, no densities were provided. Regarding building intensity, the only standard included in the plan was the maximum dwelling units per acre. There were classifications such as commercial-neighborhood, light industrial, and heavy industrial in the plan, but they provided little guidance on height or size limitations, types of buildings allowed, or permitted uses. Twain Harte Homeowners (plaintiffs) challenged the Tuolumne County General Plan as insufficient under California’s Planning and Zoning Law. The trial court found that the plan sufficiently complied with statutory requirements.