People ex rel Dept Pub Wks v. Peninsula Enterprises Inc

In People ex rel. Dept. Pub. Wks. v. Peninsula Enterprises, Inc. (1979) 91 Cal.App.3d 332, the agency's pre-RON activities evidenced an intent to acquire the property for a proposed freeway project that resulted in a substantial interference with the owner's rights. Following several refused offers to purchase the property, the agency engaged in a course of conduct to frustrate the owner's efforts to develop the property. (Id. at pp. 341-342.) The agency's activities thus "reached the acquiring rather than planning stage" despite the absence of a formal resolution of condemnation. (Id. at p. 356.) In view of this finding, the court concluded that "the freeway agreement in question should therefore be treated as the type of precondemnation announcement resulting in direct and special interference with private property with which the court in Klopping was concerned." (Ibid.)