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Pacific Palisades Bowl Mobile Estates, LLC v. Los Angeles

ELR Citation: 42 ELR 20249
Nos. S187243, (Cal., 11/29/2012)

The California Supreme Court held that all subdivisions, including the conversion of a mobile home park from tenant occupancy to resident ownership, are "developments" for purposes of the California Coastal Act. Nor does the Subdivision Map Act exempt such conversions from the need to comply with other state laws or preclude local governmental agencies from exercising state-delegated authority to require compliance with state laws. The court, therefore, upheld a city's refusal to accept an application to convert a 170-unit mobile home park located within California's coastal zone from tenant occupancy to resident ownership because the applicant failed to include applications for a coastal development permit and other state-law requirements.