Arcadia Development Co. v. City of Morgan Hill
197 Cal. App. 4th 1526
| Cal. Ct. App. | 2011Background
- Arcadia owns a 69-acre undeveloped parcel annexed to Morgan Hill in 1990; its general plan zoning is R-1 (7000) allowing 7,000 sq ft lots, but a Density Restriction limits the Arcadia parcel to 20-acre lots.
- Measure P (1990) proposed a five-year housing supply and restricted adding land to Morgan Hill’s urban service area, with a Density Restriction tying new additions to densities allowed by the pre-1990 county general plan.
- Arcadia was the only residentially developable property within Morgan Hill’s urban service area subject to the Density Restriction after annexation; other new additions were either nonresidential or exempted from the restriction.
- Measure C (2004) extended the Density Restriction to 2020, kept five-year housing supply logic, and prohibited noninfilling expansions unless advantageous to public welfare; Arcadia remained uniquely restricted.
- Arcadia sued after Measure C; the trial court found a rational basis for the restriction; the appellate court affirmed, holding the Density Restriction is not arbitrary or violative of equal protection and is related to public welfare goals.
- The court noted the Density Restriction would be reevaluated when Measure C expires in 2020 and that Arcadia’s property is distinct in size and location, making the restriction plausibly rational.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Density Restriction invalid as equal protection or police power abuse? | Arcadia asserts facially discriminatory treatment of its property. | City contends rational basis supports public welfare goals. | Not invalid; rational basis supported by public welfare aims. |
| Does the Density Restriction constitute improper spot zoning? | Arcadia argues it isolates Arcadia as a class of one. | Court finds no spot zoning given parcel size and surrounding land. | No unlawful spot zoning; arcadian size and context justify restraint. |
| Is there a rational relationship between the Density Restriction and public welfare goals? | Ardia claims no rational basis distinguishes Arcadia from others. | Restriction furthers anti-sprawl, resource burden, and rural character. | Yes; substantial relation to preventing sprawl and preserving rural character. |
Key Cases Cited
- Wilkins v. City of San Bernardino, 29 Cal.2d 332 (Cal. 1946) (spot zoning constraints in zoning ordinances; rational basis limits)
- Hamer v. Town of Ross, 59 Cal.2d 776 (Cal. 1963) (spot zoning and reasonableness review in land use)
- Arnel Development Co. v. City of Costa Mesa, 126 Cal.App.3d 330 (Cal. App. 1981) (testing rational relationship to public welfare in zoning)
- Breneric Associates v. City of Del Mar, 69 Cal.App.4th 166 (Cal. App. 1998) (planning to preserve scenic/rural character and regulate development)
- Village of Willowbrook v. Olech, 528 U.S. 562 (U.S. 2000) (class-of-one equal protection standard)
- Las Lomas Land Co., LLC v. City of Los Angeles, 177 Cal.App.4th 837 (Cal. App. 2009) (equal protection in land-use classifications)
- FCC v. Beach Communications, Inc., 508 U.S. 307 (U.S. 1993) (rational basis review; deference to legislative judgment)
- Arnel Development Co. v. City of Costa Mesa, 126 Cal.App.3d 330 (Cal. App. 1981) (duplicate entry for emphasis on public welfare)
- Fry v. City of Hayward, 701 F.Supp. 179 (N.D. Cal. 1988) (distinction of land-use treatment where open-space parcel singled out)