Mola Development Corp. v. City of Seal Beach

In Mola Development Corp. v. City of Seal Beach (1997) 57 Cal.App.4th 405, the court of appeal held in part that the administrative development-approval process that the plaintiffs had gone through--which had included a public hearing and which had led to the city's adverse land-use decision that was undisputedly quasi-judicial and adjudicatory in character--did not have to meet the formal requirements of the Administrative Procedure Act (Gov. Code, 11500 et seq.) in order for the doctrine of exhaustion of administrative remedies to apply to bar the plaintiff's action for damages. (Mola, supra, at pp. 410, 412.) In the factual context of the case, unlike here, there was an established administrative process available that included a public hearing and an opportunity for internal review and there was no issue concerning the characterization of that process as quasi-judicial. These indicia of an established administrative process and the court's characterization of that process as leading to a "quasi-judicial decision" (Id. at p. 407)