In California Coastal Com. v. Superior Court (Ham) (1989) 210 Cal. App. 3d 1488, the Coastal Commission required a coastal property owner to record an offer to dedicate an easement for public access across the strip of beach in front of his home, in return for approval of a coastal development permit. In 1985, the landowner recorded the offer to dedicate, the commission issued the permit, and the landowner completed the project. Three years later, the landowner sued the commission for inverse condemnation seeking $ 1 million in damages. He alleged the permit condition requiring dedication of a public beach access easement amounted to an unconstitutional taking of private property without compensation. The Court of Appeal issued a writ directing the trial court to sustain the commission's demurrer to the complaint, concluding that the landowner's failure to challenge the permit condition in an administrative mandamus action barred his action for damages. The court reasoned: "The primary right at issue in the administrative proceeding was Ham's 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 court added that the validity of the permit condition was at issue in the prior administrative proceeding. "Because Ham failed to contest the validity by the means provided for judicial review, he is now estopped to relitigate the same issue in the context of an inverse condemnation action." ( Id. at p. 1500, fn. 8.) The Ham court further held that as long as an agency has subject matter jurisdiction over the issue before it, its decisions are subject to res judicata even if they turn out to be incorrect. "'It is an established rule that where a tribunal has jurisdiction of the parties and of the subject-matter it necessarily has the authority and discretion to decide the questions submitted to it even though its determination is erroneous. . . . This rule applies to quasi-judicial tribunals as well as to courts.'. . . Here, the commission quite clearly had subject matter jurisdiction and the authority to impose permit conditions reasonably related to any burdens on the public beach created by the construction of Ham's residence. . . . The fact that it incorrectly analyzed the relationship between the burdens and the condition it sought to impose--or perhaps more accurately, incorrectly anticipated the action of the United States Supreme Court--does not mean it acted in excess of its jurisdiction in the fundamental sense. If he believed the commission was wrong, Ham had a remedy by way of judicial review. Having failed to avail himself of that recourse, he now has no basis for complaint." (Ham, supra, 210 Cal. App. 3d at p. 1501.)