Pac. Palisades Bowl Mobile Estates, LLC v. City of Los Angeles

This controversy arose after the City of Los Angeles refused to accept Pacific Palisades Bowl Mobile Estates’s application to convert its 170-unit mobilehome park from tenant occupancy to resident ownership because Palisades Bowl had failed to include applications for a coastal development permit or for Mello Act approval. Palisades Bowl filed a petition for writ of mandate and a complaint for injunctive and declaratory relief. The trial court granted the relief, commanding the City to evaluate the application for approval without considering whether it complied with either the California Coastal Act or the Mello Act. The court of appeal reversed. The Supreme Court affirmed, holding that the requirements of the Coastal Act and the Mello Act apply to a proposed conversion, within California’s coastal zone, of a mobilehome park from tenant occupancy to resident ownership. In so holding, the Court rejected the argument that such a conversion is not a “development” for the purposes of the Coastal Act and that Cal. Gov’t Code 66427.5 exempts such conversion from the need to comply with other state laws, or precludes local governmental agencies from exercising state-delegated authority to require compliance with state laws such as the Coastal Act or the Mello Act.

Supreme Court California – Pac. Palisades vs. City of Los Angeles