Collins v. County of Monterey Board of Supervisors

Background

James G Collins brought a quiet-title action, which is a lawsuit asking a court to determine the parties’ rights to property. He argued that a Conservation and Scenic Easement on his approximately 21-acre property in Monterey County had been terminated. The easement generally barred structures, excavation, and topographic changes, subject to limited exceptions for facilities and improvements related to an undeveloped scenic area.

The easement’s Article 7 allowed the grantor or successors in interest to terminate it if California or Monterey County enacted qualifying conservation legislation restricting, or agreeing to restrict, the property’s use for scenic or recreational purposes, natural resources, or food and fiber production. Walter and Loretta Warren recorded a 1990 termination notice based on the California Coastal Act. During the lawsuit, Collins delivered a 2019 termination notice relying on Monterey County Ordinance section 20.36.040.

Collins also argued, alternatively, that he was a good-faith purchaser for value without notice of the easement and that the County should be equitably estopped—that is, prevented from enforcing the easement because of its conduct.

Court’s Analysis

The court denied the County’s motion for judgment on partial findings under Federal Rule of Civil Procedure 52(c). The court concluded that the case should instead be resolved based on the findings described in the opinion.

The court held that Monterey County’s Resource Conservation Coastal Zone zoning ordinance was qualifying conservation legislation under Article 7. The ordinance restricted development on the property and implemented the California Coastal Act. The court concluded that the ordinance did not need to be more restrictive than the easement; it only needed to restrict the property’s use. Because the ordinance satisfied the condition required by Article 7, the court found that the easement was terminated based on Collins’s 2019 notice. The court also stated that terminating the easement did not intensify the property’s use because the property remained subject to the Resource Conservation Coastal Zone restrictions.

The court rejected Collins’s good-faith-purchaser claim. It found that the evidence established that Collins was chargeable with notice of the easement. The court relied on the property’s low purchase price compared with its estimated value without the easement, Collins’s awareness of zoning restrictions, the title insurance company’s later return of the $129,000 purchase price, and Collins’s prior property-purchasing experience.

The court also rejected equitable estoppel. It found that Collins did not show that the County intended its conduct to be relied upon or acted in a way that gave him a reasonable basis to believe that the County intended such reliance. The court further found that public-policy considerations favored the County.

Disposition

The court found that the Conservation and Scenic Easement was terminated and that Collins prevailed in his quiet-title action against the County of Monterey. The court granted Collins’s request for declaratory relief. It denied Collins’s good-faith-purchaser-for-value-without-notice claim and equitable-estoppel claim. The court stated that the case did not determine how the property should be zoned under state or county law and did not address the De Amaral Preserve. Judge Nathanael M. Cousins signed the findings and conclusions on April 21, 2021.