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City of Monterey v. California Coastal Commission

Citations: 120 Cal. App. 3d 799; 174 Cal. Rptr. 798; 1981 Cal. App. LEXIS 1881Docket: Civ. 50149

Court: California Court of Appeal; June 23, 1981; California; State Appellate Court

Narrative Opinion Summary

This case involves a dispute over the reconstruction of historic buildings on Cannery Row, following their destruction in a fire, and addresses the applicability of coastal permit requirements under the Public Resources Code. The parties include the City of Monterey and property owner Dale Runyan. Initially, Runyan sought to renovate a dangerous warehouse, requiring a coastal permit which was conditionally approved. Legal challenges arose over the conditions imposed, leading to litigation that questioned procedural fairness, resulting in a court ruling in favor of Runyan with a remand for a new hearing. However, a subsequent fire rendered the original issues moot. The appellate court ultimately dismissed the case as moot, emphasizing the need to address the 'natural disaster' exception under Public Resources Code section 30610, subdivision (g), for any future reconstruction to avoid further litigation. The court's decision highlights the complexities of coastal development permits and the impact of unforeseen events on legal proceedings.

Legal Issues Addressed

Applicability of Section 30610, Subdivision (g)

Application: The court highlighted the importance of resolving the applicability of section 30610, subdivision (g), to prevent future disputes, though it could not determine compliance without an established record.

Reasoning: The court emphasizes the importance of resolving the application of section 30610, subdivision (g) now to prevent further delays and litigation.

Coastal Permit Requirements under Public Resources Code Section 30610

Application: The court determined that the reconstruction of historic buildings destroyed by fire qualified under the 'repair' exceptions, negating the need for a coastal permit.

Reasoning: The Court of Appeals of California ruled in favor of the City of Monterey and property owner Dale Runyan, allowing the reconstruction of historic buildings on Cannery Row without requiring a coastal permit, based on the 'repair' exceptions of Public Resources Code section 30610.

Due Process in Permit Hearings

Application: The court identified a denial of fair hearing and due process in the handling of Runyan's coastal permit, prompting a remand for a new hearing.

Reasoning: Following a trial, the court favored Runyan on the mandate issue, citing denial of fair hearing and due process, and remanded the case for a new coastal permit hearing.

Mootness of Legal Issues Post-Disaster

Application: Following a fire that destroyed the buildings, the court found that the issues surrounding the 'natural disaster' exception became moot, leading to the dismissal of the judgment.

Reasoning: Following a fire on November 26, 1980, which destroyed most of the buildings, the court addressed whether Runyan qualified for the 'natural disaster' exception under section 30610, subdivision (g), ultimately determining that the matter was moot and dismissing the judgment.