DiVittorio v. County of Santa Clara

CourtDistrict Court, N.D. California
DecidedFebruary 10, 2022
Docket5:21-cv-03501
StatusUnknown

This text of DiVittorio v. County of Santa Clara (DiVittorio v. County of Santa Clara) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DiVittorio v. County of Santa Clara, (N.D. Cal. 2022).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 GAETANO DIVITTORIO and MARYANN Case No. 21-cv-03501-BLF DIVITTORIO, 8 Plaintiffs, ORDER GRANTING MOTION TO 9 DISMISS COMPLAINT WITHOUT v. LEAVE TO AMEND; AND 10 DISMISSING ACTION WITHOUT COUNTY OF SANTA CLARA, PREJUDICE 11 Defendant. [Re: ECF 18] 12

13 14 Plaintiffs Gaetano and Maryann DiVittorio (“the DiVittorios”) are a married couple who 15 purchased more than twenty acres of real property (“the Property”) in San Martin, California, for 16 the purpose of building a recreational vehicle (“RV”) park. They claim that Defendant County of 17 Santa Clara (“the County”) effectively has denied their application for approval to build an RV 18 park, as the County repeatedly has deemed the application to be incomplete even though the 19 DiVittorios allegedly have submitted all required information. After multiple application rounds, 20 the DiVittorios administratively appealed the County’s incompleteness determination. Upon the 21 denial of that appeal, the DiVittorios filed this suit, asserting a federal takings claim and related 22 state law claims against the County. 23 The County has filed a motion to dismiss the DiVittorios’ complaint under Federal Rule of 24 Civil Procedure 12(b)(1), asserting a facial challenge to subject matter jurisdiction. Specifically, 25 the County argues that based on the facts alleged in the complaint it is clear that the federal takings 26 claim is not ripe because the DiVittorios have not received a final decision on their application to 27 build an RV park. The County further argues that absent a viable federal claim, the Court should 1 motion to dismiss, the County asks that the Court stay the action under the Pullman abstention 2 doctrine. 3 Judge Lucy H. Koh, to whom the case originally was assigned, took the County’s motion 4 under submission without oral argument on October 25, 2021. See Clerk’s Notice, ECF 26. On 5 January 7, 2022, the case was reassigned to the undersigned judge. See Order Reassigning Case, 6 ECF 33. The undersigned also finds the County’s motion to be appropriate for decision without 7 oral argument. See Clerk’s Notice, ECF 35. 8 The motion to dismiss is GRANTED WITHOUT LEAVE TO AMEND and the action is 9 DISMISSED WITHOUT PREJUDICE. 10 I. BACKGROUND1 11 In October 2015, prior to purchasing the Property, the DiVittorios contacted the County for 12 information and a staff analysis regarding the feasibility of building an RV park on the Property. 13 Compl. ¶ 10, ECF 1. The County recommended that the DiVittorios pay for a letter from the 14 County’s principal planner and zoning administrator, Bill Shoe, which they did. Id. ¶ 11. Mr. 15 Shoe’s letter indicated that the Property was zoned Rural Residential (“RR”) and that an RV park 16 was a permitted use for that zoning designation, subject to obtaining a Use Permit and 17 Architecture & Site Approval (“ASA”). Id. ¶ 12. Mr. Shoe noted that the DiVittorios were 18 proposing an RV park with 325 spaces, having 15 spaces per acre, and that the last RV park 19 approved by the County had only 13 spaces per acre. Id. ¶ 14. Mr. Shoe indicated that the County 20 preferred a less dense RV park and favored “upscale RV resorts.” Id. Mr. Shoe stated, however, 21 that while land use approvals are obtained through the County, building and development 22 approvals for RV parks are obtained through the State. Id. ¶ 16. 23 Based on the information provided by Mr. Shoe, the DiVittorios proceeded with the 24 purchase of the Property. Compl. ¶ 17. The DiVittorios then participated in multiple pre- 25 application meetings with the County during which the County’s principal planner, Manira 26 1 The allegations of the complaint are accepted as true for purposes of evaluating the County’s 27 facial challenge to subject matter jurisdiction. See Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1 Sandhir, advised that the number of RV spaces would need to be reduced to 13 per acre. Id. ¶¶ 19- 2 21. Ms. Sandhir also informed the DiVittorios for the first time that, pursuant to County 3 ordinance, at least 65% of the total spaces would be limited to occupancy of 30 days or less and 4 that no RVs would be allowed to remain longer than 360 days. Id. ¶ 22. The DiVittorios believe 5 that those restrictions violate state law allowing for long term stays by RV residents. Id. ¶ 23. Ms. 6 Sandhir objected to 10 employee housing units, stating that employee housing had to be limited to 7 one single-family residence and one secondary dwelling of up to 1,200 square feet. Id. ¶ 24. 8 The DiVittorios agreed to reduce the number of RV spaces to 288, with 14 spaces per acre, 9 and to reduce the number of employee housing units from 10 to 6. Compl. ¶¶ 27. The County 10 advised that the number of RV spaces was still too great and that the housing units had to be 11 reduced to one single family residence and one additional dwelling of up to 1,200 square feet. Id. 12 ¶ 28. The County also required processing fees of $13,874. Id. 13 After participating in 3 pre-application meetings with the County, the DiVittorios 14 submitted their application for a Use Permit and ASA to build the RV park on the Property. 15 Compl. ¶¶ 25, 29. The DiVittorios had reduced the number of RV spaces to 270, with 13 spaces 16 per acre. Id. ¶ 31. The County deemed the application to be incomplete, identified 30 items to be 17 completed, and requested that the DiVittorios submit 8 revised application sets. Id. ¶ 30. Many of 18 the 30 items had not been mentioned by the County during the pre-application process. Id. 19 The DiVittorios participated in a post-application meeting with the County. Compl. ¶ 32. 20 The County advised that the application was still incomplete, identifying 5 items that were 21 incomplete. Id. ¶ 34. The DiVittorios took the position that none of the 5 items rendered the 22 application incomplete. The first item was that the application used the term “residential” RV 23 park instead of a “recreational” RV park; under the applicable Rural Residential zoning a 24 “residential” RV park is not an allowed use but a “recreational” RV park is an allowed use. Id. 25 The DiVittorios assert that this quibble with semantics did not render the application incomplete. 26 Id. The second item was that the RV park density was too great at 14 spaces per acre. Id. ¶ 35. 27 The DiVittorios already had agreed to reduce the number of proposed spaces to 270, with fewer 1 identified as a multi-family development prohibited by the Rural Residential zoning. Id. ¶ 36. 2 The DiVittorios allege that the proposed employee housing clearly was identified as single family 3 residences, which they claim are permitted by right without any need for a Use Permit under the 4 County’s ordinances. Id. The fourth item was a failure to provide adequate information to review 5 the project against the RV Park Guidelines and the San Martin Integrated Design Plan and 6 Guidelines. Id. ¶ 37. The DiVittorios allege that the County did not specify what those 7 deficiencies actually were, and that the local guidelines are preempted by the State of California in 8 The Special Occupancy Parks Act. Id. The fifth item was identified as loss of viable agricultural 9 lands. Id. ¶ 38. The DiVittorios allege that the County did not identify any further information it 10 needed. To the extent the County proposed to deny the application due to a preference for 11 agricultural lands, the DiVittorio allege that the RV park was a permitted use under the applicable 12 zoning and there was nothing incomplete about their application for such use. Id.

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Bluebook (online)
DiVittorio v. County of Santa Clara, Counsel Stack Legal Research, https://law.counselstack.com/opinion/divittorio-v-county-of-santa-clara-cand-2022.