California Coastal Com. v. Superior Court

In California Coastal Com. v. Superior Court (1989) 210 Cal. App. 3d 1488, the court held a final decision of the Coastal Commission adverse to a property owner precluded the property owner from later suing the Coastal Commission for inverse condemnation. "Where judicial review is not sought and the administrative decision becomes final, application of traditional principles of res judicata and/or collateral estoppel require that the property owner be precluded from relitigating the validity of the Commission decision or seeking alternative forms of relief in a different proceeding." (Id. at p. 1493.) The property owner's primary right at issue in the administrative proceeding before the Coastal Commission was the right not to have his private property taken by the government for public purposes without compensation. "That is the same primary right he asserts in his inverse condemnation action, although he now seeks a different type of relief." (Id. at p. 1499.) The Coastal Commission's decision therefore barred the inverse condemnation action under principles of res judicata. The court issued a writ directing the superior court to sustain the Coastal Commission's demurrer to the inverse condemnation lawsuit. (Id. at p. 1502.)