Youngblood v. Board of Supervisors of San Diego County. Supreme Court of California, 1978.

Facts: On Dec. 10, 1974 the Board approved a tentative subdivision map (with conditions) for the 217-acre Rancho Del Dios development, allowing 131 lots of at least 1 acre (with overall density of .6 dwelling units per acre due to reserved undeveloped land), in compliance with zoning and the general plan at that time. On Dec. 31, however, the County amended the general plan to require 2-acres per dwelling unit in this area, but did not amend the zoning plan. In October 1975, the County approved the final subdivision map complying with the approved tentative map and its conditions. Two neighbors challenged the county for 1) failing to re-zone the land in accordance with the general plan, 2) approving the tentative subdivision plan, 3) approving the final subdivision plan.

Procedure: Two mandamus actions against the Board of Supervisors were rejected in the Superior Court and consolidated for this appeal. Prior to appeal, County did re-zone the land to comply with the general plan, so plaintiffs’ first point is moot.

Issue: At what point in the subdivision process—approval of tentative map (AKA preliminary plat) or of final plan (AKA final plat)—does the owner’s ability to subdivide land become vested?

Holding: Superior Court holding was affirmed; the County’s approval of the tentative and final plans upheld.

Rationale: Approval of the tentative map is ajudicatory and determines compliance with applicable regulations; approval of the final map is ministerial and determines compliance with tentative map and any conditions previously set forth. Therefore, the applicable regulations for the subdivision are the general plan and zoning at the time of the tentative map approval.

Notes: There’s a confusing bit in here. The court refers to one of the Planning Commission’s conditions of the tentative subdivision map approval being “application for zoning change from A-4(1) to E-1(B) (1-acre residential).” I don’t know how this squares with the County’s subsequent re-zoning to “conform with the general plan.” Maybe the condition was application for the change, not approval?
Timeline:
· June 26 1974: Santa Fe Company applies for a tentative subdivision map for the property.
· Oct. 11 1974: San Diego County Planning Commission approves the tentative map with conditions, including requirement to apply for a zoning change.
· Dec. 10 1974: San Diego County Board of Supervisors approves the tentative map with Planning Commission’s conditions.
· Dec. 31 1974: County general plan amended.
· Apr. 24 1975: Board of Supervisors determines Santa Fe Co. has complied with condition requifing application for zoning change.
· Oct. 25 1975: Board of Supervisors approves final subdivision map.