Santa Clara County Contractors etc. Assn. v. City of Santa Clara

In Santa Clara County Contractors etc. Assn. v. City of Santa Clara (1965) 232 Cal.App.2d 564, the court held that a subdivision ordinance imposing fees of $25 for each dwelling or apartment unit up to a maximum of $100 for each one-fifth of an acre, and $8.50 for each trailer space, both fees to be paid into a "Capital Outlay Recreational Fund," did not serve its stated purpose of supplementing the Subdivision Map Act in order to insure local conformity therewith. ( Id. at pp. 571-572.) Instead these fees were held to be contrary to the terms of the Subdivision Map Act and the fact that the defendant municipality was a chartered city was held to be without consequence. ( Id. at p. 575.) The court treated the fees as a nonmunicipal matter of statewide concern within an area that the general law (the Subdivision Map Act) had occupied completely. ( Id. at pp. 576, 580.)