Youngblood v. Board of Supervisors of San Diego County

The Board of Supervisors of San Diego County (Board) (defendant) approved a tentative subdivision map on December 10, 1974, with certain conditions, in accordance with the general map in effect at the time. On December 31, 1974, San Diego County amended its general plan to limit density in the subdivision area. Thus, when the Board approved the final subdivision map on October 25, 1975, the subdivision did not conform to the existing general plan. James Youngblood and other neighbors of the subdivision (plaintiffs) filed mandamus actions against the Board, arguing that the Board had acted illegally to approve the tentative and final maps and that the Board was required to rezone the subdivision to conform to the new general plan. The trial court affirmed the Board’s decision, and the plaintiffs appealed. The Board did rezone the subdivision while the plaintiffs’ appeal to the Supreme Court of California was pending. Therefore, the only issues to be reviewed were the approval of the tentative and final maps. The plaintiffs argued that (1) the tentative map, contrary to what the record showed, was not approved until April 1975, after the new general plan was enacted, and therefore should not have been approved because the tentative map did not conform to the existing general plan, and (2) the final map should not have been approved because the final map did not conform to the existing general plan.