A recent court decision has affirmed that a homeowners' association must exhaust all administrative remedies before seeking judicial intervention. On May 30, 2024, the Casa Blanca Beach Estates Owners’ Association filed a complaint in the Court of Appeal of the State of California against the County of Santa Barbara and the California Coastal Commission. The case centers around an obligation to construct a beach access walkway, which was part of an offer to dedicate recorded in 1990.
The Casa Blanca Beach Estates Owners’ Association (Casa Blanca) manages a 12-lot oceanfront subdivision in Carpinteria approved by the County of Santa Barbara Planning Commission over three decades ago. A condition for this development required Casa Blanca’s predecessor to provide an irrevocable offer to dedicate a lateral access easement for public beach access and construct a concrete walkway within 180 days after acceptance of the offer. The County accepted this offer in 2011, but it wasn't until 2017 that they, along with the Commission, notified Casa Blanca that they had missed the deadline to build the walkway.
Casa Blanca responded by submitting construction plans, only to be informed that they needed a coastal development permit from the Commission. Despite applying for this permit, their application was deemed incomplete. After years of back-and-forth without resolution, Casa Blanca filed for declaratory relief and petitioned for writ of mandate against both entities in September 2018.
During litigation in May 2019, Casa Blanca withdrew an appeal regarding their incomplete application at the Commission's request to explore alternative construction options. However, further study proved unfruitful. By November 2019, cross motions for summary judgment were heard; the trial court ruled in favor of the County on all causes and denied Casa Blanca’s motion.
Subsequently, in December 2019, litigation was stayed to allow Casa Blanca time to exhaust administrative remedies. This stay was lifted in November 2020. In February 2021, Casa Blanca filed a second amended complaint adding allegations against the Commission. However, this too was dismissed on grounds that administrative remedies had not been exhausted.
Casa Blanca contends its claim is ripe as it has exhausted all available administrative remedies or is excused from doing so due to unreasonable delays by Commission staff. They seek remand directing the trial court to determine if they are currently obligated to construct the walkway.
Representing Casa Blanca are attorneys Sherman L. Stacy, Lisa A. Weinberg, and Rebecca A. Thompson from Gaines & Stacey LLP. The defendants are represented by Brian Pettit from Santa Barbara County Counsel’s Office and Rob Bonta along with his team from the Attorney General's office representing the California Coastal Commission. Judges Pauline Maxwell and Donna Geck presided over Superior Court proceedings under Case ID No. B3814102.