City of Goleta v. Superior Court

Summary

The California Supreme Court held that a newly incorporated city had discretion to disapprove a final subdivision map when the county had approved the related vesting tentative map outside the safe-harbor conditions of Government Code section 66413.5. The court also held that the city's adoption of county ordinances did not surrender that discretion and that equitable estoppel did not bar the city from denying approval. The court affirmed the judgment of the Court of Appeal.

Holdings

1. Because Sandpiper's vesting tentative map did not satisfy the temporal conditions of Government Code section 66413.5, subdivision (f), the mandatory approval obligation in subdivision (a) did not apply. Goleta therefore retained discretion to disapprove the final map.
2. Goleta's adoption of the County's subdivision ordinances did not require ministerial approval of a final map based on a tentative map approved by the County. The City retained discretion over final maps when the County, rather than Goleta, had approved the tentative map.
3. Goleta was not equitably estopped from disapproving Sandpiper's final map.

Questions Presented

1. Whether a newly incorporated city has discretion to disapprove a final subdivision map when the county approved the vesting tentative subdivision map after the incorporation election.
2. Whether Goleta's adoption of the County's subdivision ordinances required ministerial approval of Sandpiper's final map.
3. Whether Goleta was equitably estopped from disapproving the final map based on its conduct and communications concerning the project.

Disposition

affirmed