## Facts

- San Diego County approved a tentative subdivision map for the Rancho Del Dios subdivision on December 10, 1974, allowing one-acre lots under then-existing zoning and the general plan.
- On December 31, 1974, the county amended its general plan to reduce permitted density in the area to one dwelling unit per two acres.
- On October 25, 1975, the Board approved the final subdivision map for one-acre lots, which did not conform to the amended general plan.
- Neighboring landowners filed consolidated mandamus actions challenging approval of the tentative and final maps and seeking to compel rezoning to match the amended general plan.
- The trial court sustained a general demurrer without leave to amend in one action and, in the other, sustained a demurrer/stayed the case based on another action pending.
- During the appeal, the county rezoned the property to conform to the amended general plan, leaving the map-approval disputes as the remaining live controversy.

## Issues

1. Whether plaintiffs stated a sufficient basis to treat the tentative map as approved after the general plan amendment, rather than on the approval date shown in the county’s official record.
2. Whether the Board could lawfully approve a final subdivision map that was inconsistent with the general plan in effect at the time of final map approval.
3. Whether the request to compel rezoning remained justiciable after the county rezoned the property during the appeal.

## Decision

- The court treated the tentative map as validly approved on December 10, 1974, because the official record reflected that approval and plaintiffs’ contrary allegations were conclusory.
- The court held the Board could not approve the final map in October 1975 because it did not conform to the then-effective general plan’s two-acre density requirement.
- The court concluded the rezoning claim was moot because the county had already rezoned the property to conform to the amended general plan.
- The court reversed the dismissals and remanded with directions to grant mandamus relief setting aside the final map approval, and to resolve the related consolidated action consistently.

## Legal Principles

- A local general plan is a legally controlling land-use instrument; discretionary land-use approvals must be consistent with the general plan.
- Under the Subdivision Map Act and related planning statutes, approval of a final subdivision map must conform to the general plan in effect at the time of final approval.
- Approval of a tentative map does not, by itself, authorize subdivision and does not immunize a later final map from compliance with subsequently adopted general plan requirements.
- Courts generally accept an agency’s official records of action (e.g., minutes and resolutions) absent specific factual allegations showing a legal defect sufficient to overcome the record.
- A claim for mandamus becomes moot when the requested governmental action has already been taken.

## Conclusion

The court upheld the tentative map approval date reflected in the county record but held the county lacked authority to approve a final subdivision map inconsistent with the general plan in effect at final approval, ordering mandamus to set aside the final map approval while dismissing the rezoning request as moot.


Youngblood v. Bd. of Supervisors of San Diego Cnty., 22 Cal. 3d 644, 586 P.2d 556 (Cal. 1978)