Gardner v. County of Sonoma

In 1865, Greene recorded a map dividing his land into lots, at a time before any subdivision-map law existed, so the map was recorded in Sonoma County (defendant) without any public review. California's first subdivision-map law came in 1893, later followed by the Subdivision Map Act (SMA), which generally bars selling or financing subdivision parcels unless recorded on a lawfully approved map, subject to exceptions for parcels that complied with or were exempt from subdivision laws in effect when created. The Gardners (plaintiffs), who came to own 158 acres of Greene's former property, sought recognition of it as 12 separately sellable parcels based on Greene's 1865 map, but the land had always been conveyed as a single unit since 1865. County agencies and the courts below rejected the Gardners' claim, and the Gardners appealed, arguing two specific SMA provisions compelled recognizing the 12 parcels.