City of Morgan Hill v. Garcia CA6

CourtCalifornia Court of Appeal
DecidedOctober 21, 2025
DocketH052498
StatusUnpublished

This text of City of Morgan Hill v. Garcia CA6 (City of Morgan Hill v. Garcia CA6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Morgan Hill v. Garcia CA6, (Cal. Ct. App. 2025).

Opinion

Filed 10/21/25 City of Morgan Hill v. Garcia CA6

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

CITY OF MORGAN HILL, H052498 (Santa Clara County Plaintiff and Respondent, Super. Ct. No. 21CV385524)

v.

W. ROCKE GARCIA et al.,

Defendants and Appellants.

This case involves the City of Morgan Hill’s (City) condemnation action over an undeveloped, 4.088-acre parcel of land (the property) owned by W. Rocke Garcia and Glenda Garcia (together, defendants1). The City filed the action to acquire the property for purposes of a regional road extension. At issue is the amount of just compensation owed to defendants for the property. The parties’ expert appraisals diverged significantly. The City’s valuation of $3.74 million assumed a fair market value based on comparable undeveloped and unentitled land. Defendants’ valuation of $8.01 million assumed that, but for the road extension project, there was a reasonable

1 For ease of reference, we refer to W. Rocke Garcia and Glenda Garcia

together as “defendants.” We use “Garcia” to refer to W. Rocke Garcia individually. probability that defendants would have obtained entitlements to develop the property as of the date of valuation. Defendants thus assumed a fair market value based on comparable land with land use entitlements. Prior to trial, the trial court granted the City’s Code of Civil Procedure2 section 1260.040 motion to resolve legal issues affecting the determination of compensation. The court’s ruling precluded defendants from introducing at trial evidence to support their theory of valuation and resulting appraisal analysis. Faced with the inability to introduce evidence to support their theory of just compensation, defendants stipulated to judgment using the City’s valuation based on unentitled land value and reserved the right to appeal. On appeal, defendants contend the trial court erred as a matter of law by adopting a valuation method that conflicts with key principles governing the determination of just compensation in eminent domain proceedings. The City disputes the de novo standard of review proposed by defendants and maintains the court did not abuse its discretion in barring the introduction of evidence to support the defendants’ valuation methodology. For the reasons explained herein, we decide the trial court did not abuse its discretion in granting the City’s motion and affirm the judgment. I. FACTS AND PROCEDURAL BACKGROUND A. The Property The property is a narrow, curved parcel of approximately four acres of undeveloped land in a residential neighborhood near downtown Morgan Hill. In 1976, Garcia, an experienced developer and home builder, acquired the property and adjacent land (referred to as “Spring Hill”) with the intention of developing it for housing. Garcia learned prior to completing the purchase

2 All further unspecified references are to the Code of Civil Procedure.

2 that the property was the location of a planned road extension of Santa Teresa Boulevard and Hale Avenue (the road extension), which had been identified as a planned arterial in the City’s general plan since 1969. The city manager at the time informed Garcia that the property should be held for later purchase by the City. Based on this information, Garcia did not expect to build homes on the property portion of the land acquired. In 1979, after Garcia had subdivided and developed the land to the north and south of the property, the City approved the 30-lot subdivision map for “Spring Hill Estates 3.” Spring Hill Estates 3 included 28 lots for single family homes, reserved one lot (Lot 30) for future development, and designated the area comprising the property as “Lot 29.” The property appeared on the subdivision map as “Lot 29” – “ ‘Future Santa Teresa’ ” in the narrow and curved shape of the road extension. The shape of Lot 29 was dictated by the shape of the road extension. Had the City not required the property to be set aside for the road extension, Garcia asserts that he would have integrated the development of Lot 29 with that of Lots 1 through 28 in Spring Hill Estates 3. B. City Planning Measures In 1977 (the year after defendants purchased the property), the City’s voters adopted by initiative the first in a series of residential development control system (RDCS) ordinances designed to limit population growth and provide a method for evaluating proposed residential developments. Measure C, codified as section 18.78.020 of the City’s municipal code, is the relevant version of the City’s RDCS. Measure C restricted residential development in the City to a system of development allotments and established a competition for allocating the limited number of allotments each year. The City awarded development allotments to the projects that received the highest scores in the

3 competition. A property owner could not file a tentative subdivision map unless the owner had first applied for and been awarded a development allotment by the City. Measure C further required the City’s planning officer to review each application for development allotment for conformity with the City’s general plan.3 If the planning officer determined the proposed development did not conform to the general plan, the application would be rejected. At least since 1980, the circulation element of the City’s general plan has depicted a planned road extension across the property. In 1996, while developing Lot 30 of Spring Hills Estates 3, Garcia discovered that a condition for offer of dedication had been imposed on the 1979 subdivision map. The condition apparently required defendants to offer to dedicate Lot 29 when Lot 30 was developed. In October 1997, the city council rescinded by resolution the dedication requirement.4 In 1998, the City recorded a quitclaim deed releasing any City rights to the property. The

3 California law requires that each city adopt a general plan that is a

long-range, comprehensive policy statement of a community’s physical development. (Gov. Code, § 65300.) A general plan must include land use, circulation, housing, conservation, open space, noise, safety, and environmental justice elements. (Id., § 65302.) The circulation element of the general plan must show the “location and extent of existing and proposed major thoroughfares” and other public utilities, correlated with the land use element of the plan. (Id., subd. (b).) 4 Resolution No. 5126, adopted by the City on October 15, 1997, states,

inter alia, that the city council “has declined to purchase Lot 29, as future Santa Teresa right-of-way,” “desires to rescind the . . . condition as listed” on the subdivision map, and “in order to facilitate development of Lot 29, the [c]ity [c]ouncil hereby authorizes and directs the [c]ity [m]anager to execute a quitclaim deed” that “will convey any and all rights that the City may have in Lot 29 to its present owner.” 4 record does not show any action or steps taken by defendants between 1998 and 2013 toward developing the property. C. Implementation of the Road Extension and Measure C Application In 2007, the City took steps toward implementing the road extension. City staff included the road extension in the capital improvement program budget from 2007 through 2012. In 2008, the City purchased for $1,141,359 two acres immediately north of the property for the road extension. However, in 2012, City funding for the road extension project was eliminated due to the dissolution of the state’s redevelopment agencies.

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City of Morgan Hill v. Garcia CA6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-morgan-hill-v-garcia-ca6-calctapp-2025.