49 Cal.App.5th 284
Cal. Ct. App.2020Background
- Plaintiffs (SLPR, Goodfellow, Sewall) own Coronado bayside parcels and sued State and the Port alleging property damage from Navy (1998, 2002) and Army (2004–05) dredging projects and asserting quiet title, inverse condemnation, nuisance, and lateral-support claims.
- A 1931 "Spreckels" judgment (entered in an earlier quiet-title action between Coronado and Spreckels interests) described the mean high tide line (MHTL) by a detailed courses-and-distances survey but was facially ambiguous whether it fixed the boundary or merely located the MHTL at that time.
- This court’s prior opinion (SLPR I) held the Spreckels judgment ambiguous and reversed summary judgment, finding triable issues about whether the judgment fixed boundaries and whether State substantially participated in dredging projects.
- On remand Plaintiffs filed a third amended complaint (TAC). The trial court admitted extensive extrinsic evidence (surveys, city minutes, engineer letters, maps) and concluded the Spreckels judgment fixed the tideland boundary, so res judicata barred Plaintiffs’ quiet title-related claims; the court also sustained State’s demurrer to the inverse-condemnation, nuisance, and lateral-support claims as time-barred under Public Resources Code § 30801.
- The Court of Appeal affirmed: it independently reviewed the extrinsic record, held the 1931 judgment fixed the boundary (so res judicata applied), and agreed the 60‑day administrative‑mandamus requirement barred the other claims for failure to timely challenge CCC concurrences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Spreckels 1931 judgment is ambiguous and, if clarified by extrinsic evidence, bars Plaintiffs’ quiet title and related inverse‑condemnation claims by res judicata | The judgment is ambiguous and cannot be so interpreted as to preclude Plaintiffs; extrinsic proof should be limited to the prior case record | The judgment may be clarified by relevant extrinsic evidence showing parties intended to fix the boundary; res judicata applies if so | Held for State: extrinsic evidence (surveys, council minutes, maps, monuments, legislative reliance) shows parties intended to fix the boundary; res judicata bars quiet title and related claims |
| Scope and admissibility of extrinsic evidence to interpret an ambiguous judgment | Limiting admissible evidence to the four corners (judgment and original record) | All relevant extrinsic evidence that shows the parties’ objective mutual intent is admissible | Held for State: California law permits extrinsic evidence beyond the original record to determine mutual intent; court independently construed the unconflicted extrinsic evidence |
| Whether artificial‑accretion doctrine or local artificial improvements support interpreting the judgment as fixing the boundary | Plaintiffs argued ambiguity and other interpretations (ambulatory MHTL) control | Defendants relied on evidence of wharves/fill and surveys locating pre‑fill MHTL to apply the artificial‑accretion rule and justify a fixed line | Held for State: evidence showed artificial improvements/fill in immediate vicinity and parties intended a fixed metes‑and‑bounds line; artificial‑accretion doctrine supports state ownership of artificial accretions |
| Whether Plaintiffs’ inverse‑condemnation, nuisance, and lateral‑support claims against State are barred for failure to file an administrative‑mandamus petition within 60 days under Pub. Resources Code § 30801 | Plaintiffs contend their tort/inverse claims survive and SLPR I left triable issues about State’s substantial participation | State argues PRC § 30801 requires a petition for writ of administrative mandamus within 60 days of CCC action (concurrence), and failure to do so precludes collateral attack | Held for State: TAC’s claims are premised on CCC concurrences or failures to object; Plaintiffs did not timely file a §1094.5 petition within 60 days, so §30801 bars those claims (demurrer properly sustained) |
Key Cases Cited
- State of Cal. ex rel. State Lands Com. v. Superior Court, 11 Cal.4th 50 (Cal. 1995) (announcing and explaining California's artificial‑accretion rule and limiting "artificial" to human acts in the immediate vicinity)
- Pacific Gas & Elec. Co. v. G.W. Thomas Drayage etc. Co., 69 Cal.2d 33 (Cal. 1968) (extrinsic evidence admissible to show a meaning to which written instrument is reasonably susceptible)
- Mycogen Corp. v. Monsanto Co., 28 Cal.4th 888 (Cal. 2002) (elements and effect of res judicata/claim preclusion)
- Federation of Hillside & Canyon Assns. v. City of Los Angeles, 126 Cal.App.4th 1180 (Cal. Ct. App. 2004) (res judicata requires final prior judgment on same cause and same parties or privity)
- Serra Canyon Co. v. California Coastal Com., 120 Cal.App.4th 663 (Cal. Ct. App. 2004) (administrative mandamus under §1094.5 is the proper remedy for challenging CCC decisions; failure to seek that remedy precludes inverse‑condemnation claims)
- Pacific Shores Property Owners Assn. v. Dept. of Fish & Wildlife, 244 Cal.App.4th 12 (Cal. Ct. App. 2016) (distinguishing claims based on administrative action from physical invasion/damage)