Laguna Terrace Park v. California Coastal Commission
Laguna Terrace Park LLC (Laguna Terrace) appeals from the judgment entered after the trial court denied its petition for a writ of mandate and damages and a complaint for declaratory and injunctive relief (the petition) against the California Coastal Commission (the Commission). The trial court rejected Laguna Terrace’s challenge to the Commission’s determination that it had jurisdiction, under the California Coastal Act of 1976 (Pub. Resources Code, § 30000 et seq.; hereafter, the Coastal Act), over Laguna Terrace’s proposed conversion of a mobilehome park from tenant occupancy to resident ownership.
Laguna Terrace argues (1) the proposed conversion did not constitute a development within the meaning of the Coastal Act (Pub. Resources Code, § 30106), and was otherwise exempt from the Coastal Act’s requirements under the Subdivision Map Act (Gov. Code, §§ 66410‑66499.37); (2) the Commission wrongfully asserted jurisdiction by considering property beyond the boundaries of the mobilehome park itself; (3) the trial court erroneously failed to grant Laguna Terrace’s requests to augment the record with or take judicial notice of the City of Laguna Beach’s (the City) administrative record; and (4) the court wrongfully denied Laguna Terrace’s request for a statement of decision.
We affirm. After initial briefing had concluded in this appeal, the California Supreme Court issued its opinion in Pacific Palisades Bowl Mobile Estates, LLC v. City of Los Angeles (2012) 55 Cal.4th 783, 792 (Pacific Palisades). The Supreme Court rejected the primary argument asserted by Laguna Terrace, here, and held the conversion of a mobilehome park from tenant occupancy to resident ownership is a development for purposes of the Coastal Act. The Supreme Court further held that Government Code section 66427.5 of the Subdivision Map Act does not provide an exemption for such a development. (Pacific Palisades, supra, at p. 792.)
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