William S. Hart Union High School District v. Regional Planning Commission

226 Cal. App. 3d 1612, 277 Cal. Rptr. 645, 91 Daily Journal DAR 1146, 91 Cal. Daily Op. Serv. 784, 1991 Cal. App. LEXIS 67
CourtCalifornia Court of Appeal
DecidedJanuary 25, 1991
DocketB041735
StatusPublished
Cited by25 cases

This text of 226 Cal. App. 3d 1612 (William S. Hart Union High School District v. Regional Planning Commission) 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
William S. Hart Union High School District v. Regional Planning Commission, 226 Cal. App. 3d 1612, 277 Cal. Rptr. 645, 91 Daily Journal DAR 1146, 91 Cal. Daily Op. Serv. 784, 1991 Cal. App. LEXIS 67 (Cal. Ct. App. 1991).

Opinion

Opinion

CROSKEY, J.

By their petition filed in this action, appellants, the William S. Hart Union High School District and the Saugus Union School District (referred to hereinafter collectively as the school districts), seek to stop the development of land which lies within the County of Los Angeles because they believe they have insufficient school facilities to accommodate the projected number of students which the development will bring to their schools. The respondent county agencies and the proponents of the development project demurrered to the petition and their demurrers were sustained without leave to amend. As we find that the County of Los Angeles is not limited by the 1986 school facilities legislation (hereafter 1986 School Facilities Legislation) 1 in the exercise of its legislative authority to approve or deny proposed zoning changes, we will conclude that the school districts should be given the opportunity to allege that the county, when it approved the zoning change involved here, did so under the erroneous belief that such action was required by state law. We therefore reverse the trial court’s order of dismissal and remand the cause for further proceedings.

*1616 Statement of the Alleged Facts

1. The Respondents

According to the petition filed in this action by the school districts, 2 respondent Regional Planning Commission of the County of Los Angeles (the planning commission) is the planning and advisory agency for the County of Los Angeles (the County) and is responsible in part for (1) approving, conditionally approving or denying applications for development and (2) determining that proposed development conforms to stated policies of the County’s general plan and applicable specific plans.

Respondent Los Angeles County Planning Director (the planning director) is the director of the County’s planning department and is responsible for making preliminary recommendations on development applications. Respondent board of supervisors (the board of supervisors or the board) is the governing body of the County and is responsible for hearing appeals and reviewing decisions of the planning commission and for making final determinations on development projects.

2. The Real Parties in Interest

Real parties in interest, Shapell/Monteverde Partnership, Shapell Industries, Inc., and Monteverde Development Company, Inc. (real parties), are developers who are owners of real property (the subject property) in an area of the County known as the Santa Clarita Valley, in the Sand Canyon Zoned District. Real parties submitted applications to the planning commission and the board of supervisors for development of their property. They seek to use it for development of residential dwellings.

3. The County’s General Plan

The County’s 1980 (current) general plan includes a development monitoring system (DMS). The DMS sets forth specific mandatory guidelines which must be followed before the planning director, the planning commission and the board of supervisors can approve development projects that are within urban expansion areas, such as the Santa Clarita Valley. Inclusion of *1617 the DMS in the County’s general plan is the result of a lawsuit (case No. C366464) filed in 1985 which had challenged the sufficiency of the general plan as it existed at the time of that lawsuit. Since real parties’ property is within the Santa Clarita Valley, development of it is governed by the mandatory guidelines set out in the DMS.

4. The County’s Approval of Real Parties’ Proposed Development

In 1987 real parties filed an application (the application) for approval of a conditional use permit, zone changes, a local plan amendment, a development agreement and a tentative subdivision tract map for the subject property. Collectively, these authorizations would enable real parties to develop the subject property. The planning director and the planning commission prepared DMS reports for that application. Those reports acknowledged that school classroom supply was not adequate and that there was a potential significant impact on the school districts from the proposed development.

A hearing on real parties’ application was set and school districts submitted written opposition. School districts argued that approval of the development applications would violate the DMS and would be inconsistent with the County’s general plan because adequate infrastructure was not available to serve the development, and mitigation measures had not been imposed, as required by the DMS. The commission held a hearing on the matter. At that time, the commission directed its staff to prepare findings and conditions. Later, the commission approved the application, subject to real parties’ acceptance of certain conditions imposed on the subject property.

School districts appealed the approval and hearings were held before the board of supervisors on that appeal. The board rendered a preliminary order to approve the application and instructed county counsel to prepare findings and conditions for final approval and adoption by the board. Later, the board adopted the findings and approved the application.

According to the school districts’ petition, respondents acted arbitrarily, capriciously and in abuse of their discretion by approving real parties’ application. School districts allege that the approval violates the County’s general plan which, through its DMS, requires the planning commission and the board of supervisors to make findings, which are supported by substantial evidence, that (1) the proposed development conforms to established criteria and methodology for infrastructure, access and environment, and (2) the development is consistent with policies set forth in the DMS. *1618 According to school districts, there is no substantial evidence to support those findings which were in fact made by respondents.

In addition, the planning commission and the board are required (by the general plan and the DMS) to deny approval of a development project if mitigation measures are not sufficient to overcome the adverse impact on school facilities that a proposed development will bring. The petition alleges that even though respondents acknowledged that school facilities are inadequate to meet the needs of the proposed development, they have not required adequate mitigation measures as a condition of their approval. School districts further allege that respondents had a duty to follow the procedures set forth in the DMS and to only approve developments that are consistent with the general plan. The school districts allege that respondents’ actions violate the requirements of the court order in case No. C366464.

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Bluebook (online)
226 Cal. App. 3d 1612, 277 Cal. Rptr. 645, 91 Daily Journal DAR 1146, 91 Cal. Daily Op. Serv. 784, 1991 Cal. App. LEXIS 67, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-s-hart-union-high-school-district-v-regional-planning-commission-calctapp-1991.