Strong v. County of Santa Cruz

Summary

The California Supreme Court considered whether Santa Cruz County was equitably estopped from asserting that a mobile-home-park use permit had expired after county officials approved construction plans. The court held that estoppel did not apply because the developer knew the permit had expired and the evidence did not support the trial court’s findings regarding a routine extension. The judgment compelling the county to permit construction under the original permit was reversed.

Holdings

1. The County was not equitably estopped from asserting that the use permit had expired because Strong knew the permit had expired when he sought the approvals on which the estoppel claim was based, and the evidence did not support the trial court's findings that an extension would have been granted or that Strong justifiably relied on the County's conduct.
2. The County could not waive requirements of an ordinance enacted for the public benefit, and the trial court's conclusion that the County waived its right to require an extension application was untenable.
3. The court did not reach whether Strong would have acquired vested rights preventing amendment of the permit because the permit was invalid after its expiration in April 1972.

Questions Presented

1. Whether the County was equitably estopped from asserting that the mobile home park use permit had expired because it approved grading, construction plans, and sewer hookups after or near the permit's expiration.
2. Whether the County waived the ordinance and permit requirements concerning expiration and extension of the use permit.
3. Whether Strong had vested rights preventing the County from amending the permit.

Disposition

reversed