ASSOCIATED HOME BUILDERS ETC. v. City of Walnut Creek

484 P.2d 606, 4 Cal. 3d 633, 94 Cal. Rptr. 630, 43 A.L.R. 3d 847, 1 Envtl. L. Rep. (Envtl. Law Inst.) 20223, 2 ERC (BNA) 1490, 1971 Cal. LEXIS 347
CourtCalifornia Supreme Court
DecidedApril 26, 1971
DocketS.F. 22787
StatusPublished
Cited by111 cases

This text of 484 P.2d 606 (ASSOCIATED HOME BUILDERS ETC. v. City of Walnut Creek) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ASSOCIATED HOME BUILDERS ETC. v. City of Walnut Creek, 484 P.2d 606, 4 Cal. 3d 633, 94 Cal. Rptr. 630, 43 A.L.R. 3d 847, 1 Envtl. L. Rep. (Envtl. Law Inst.) 20223, 2 ERC (BNA) 1490, 1971 Cal. LEXIS 347 (Cal. 1971).

Opinion

Opinion

MOSK, J.

Section 11546 of the Business and Professions Code authorizes the governing body of a city or county to require that a subdivider must, as a condition to the approval of a subdivision map, dedicate land or pay fees in lieu thereof for park or recreational purposes. In this class action for declaratory and injunctive relief, Associated Home Builders of the Greater East Bay, Incorporated (hereinafter called Associated) 1 challenges the constitutionality of section 11546 as well as legislation passed by the City of Walnut Creek to implement the section. It is also asserted that the city’s enactments do not comply with the requirements set forth in the section. The trial court found in favor of the city, and Associated appeals from the ensuing judgment.

Section 11546 of the Business and Professions Code provides:

“The governing body of a city or county may by ordinance require the dedication of land, the payment of fees in lieu thereof, or a combination of both, for park or recreational purposes as a condition to the approval of a final subdivision map, provided that:
*636 “(a) The ordinance has been in effect for a period of 30 days prior to the filing of the tentative map of the subdivision.
“(b) The ordinance includes definite standards for determining the proportion of a subdivision to be dedicated and the amount of any fee to be paid in lieu thereof.
“(c) The land, fees, or combination thereof are to be used only for the purpose of providing park or recreational facilities to serve the subdivision.
“(d) The legislative body has adopted a general plan containing a recreational element, and the park and recreation facilities are in accordance with definite principles and standards contained therein.
“(e) The amount and location of land to be dedicated or the fees to be paid shall bear a reasonable relationship to the use of the park and recreational facilities by the future inhabitants of the subdivision.
“(f) The city or county must specify when development of the park or recreational facilities will begin.
“(g) Only the payment of fees may be required in subdivisions containing fifty (50) parcels or less.
“The provisions of this section do not apply to industrial subdivisions.”

Section 10-1.516 of the Walnut Creek Municipal Code, which will be discussed infra, refers to a general park and recreational plan adopted by the city. It provides that if a park or recreational facility indicated on the general plan falls within a proposed subdivision the land must be dedicated for park use by the subdivider in a ratio (set forth in a resolution) determined by the type of residence built and the number of future occupants. Pursuant to the ratio, two and one-half acres of park or recreation land must be provided for each 1,000 new residents. If, however, no park is designated on the master plan and the subdivision is within three-fourths of a mile radius of a park or a proposed park, 2 or the dedication of land is not feasible, the subdivider must pay a fee equal to the value of the land which he would have been required to dedicate under the formula. 3

*637 Section 11546 and the city’s ordinance are designed to maintain and preserve open space for the recreational use of the residents of new subdivisions. The adoption of a general plan (subd. (d)) avoids the pitfall of compelling exactions from subdividers of land which may be inadequate in size or unsuitable in location or topography for the facilities necessary to serve the new residents. Under the legislative scheme, the park must be in sufficient proximity to the subdivision which contributes land to serve the future residents. Thus subdividers, providing land or its monetary equivalent, afford the means for the community to acquire a parcel of sufficient size and appropriate character, located near each subdivision which makes a contribution, to serve the general recreational needs of the new residents.

If a subdivision does not contain land designated on the master plan as a recreation area, the subdivider pays a fee which is to be used for providing park or recreational facilities to serve the subdivision. One purpose of requiring payment of a fee in lieu of dedication is to avoid penalizing the subdivider who owns land containing an area designated as park land on the master plan. It would, of course, be patently unfair and perhaps discriminatory to require such a property owner to dedicate land, while exacting no contribution from a subdivider in precisely the same position except for the fortuitous circumstance that his land does not contain an area which has been designated as park land on the plan.

Constitutionality of Section 11546

Associated’s primary contention is that section 11546 violates the equal protection and due process clauses of the federal and state Constitutions in that it deprives a subdivider of his property without just compensation. It is asserted that the state is avoiding the obligation of compensation by the device of requiring the subdivider to dedicate land or pay a fee for park or recreational purposes, that such contributions are used to pay for public facilities enjoyed by all citizens of the city and only incidentally by subdivision residents, and that all taxpayers should share in the cost of these public facilities. Thus, it is asserted, the future residents of the subdivision, who will ultimately bear the burden imposed on the subdivider, will be required to pay for recreational facilities the need for which stems not from the development of any one subdivision but from the needs of the community as a whole.

In order to avoid these constitutional pitfalls, claims Associated, a dedication requirement is justified only if it can be shown that the need for additional park and recreational facilities is attributable to the increase in population stimulated by the new subdivision alone, and the validity of the *638 section may not be upheld upon the theory that all subdivisions to be built in the future will create the need for such facilities.

In Ayres v. City Council of Los Angeles (1949) 34 Cal.2d 31 [207 P.2d 1], we rejected similar arguments. In that case, a city imposed upon a sub-divider certain conditions for the development of a residential tract, including a requirement that he dedicate a strip of land abutting a major thoroughfare bordering one side of the subdivision but from which there was no access into the subdivision. The subdivider insisted that he could be compelled to dedicate land only for streets within the subdivision to expedite the traffic flow therein and that no dedication could be required for additions to existing streets and highways.

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484 P.2d 606, 4 Cal. 3d 633, 94 Cal. Rptr. 630, 43 A.L.R. 3d 847, 1 Envtl. L. Rep. (Envtl. Law Inst.) 20223, 2 ERC (BNA) 1490, 1971 Cal. LEXIS 347, Counsel Stack Legal Research, https://law.counselstack.com/opinion/associated-home-builders-etc-v-city-of-walnut-creek-cal-1971.