Shear Development Co. v. Cal. Coastal Com.

── Shear Development Co. v. Cal. Coastal Com. ── Court: California Supreme Court Date: April 23, 2026 Category: General IN THE SUPREME COURT OF CALIFORNIA SHEAR DEVELOPMENT CO., LLC, Plaintiff and Appellant, v. CALIFORNIA COASTAL COMMISSION, Defendant and Respondent. S284378 Second Appellate District, Division Six B319895 San Luis Obispo County Superior Court 20CV-0431 April 23, 2026 Chief Justice Guerrero authored the opinion of the Court, in which Justices Corrigan, Liu, Kruger, Groban, Evans, and Stone* concurred. * Associate Justice of the Court of Appeal, Second Appellate District, Division Seven, assigned by the Chief Justice pursuant to article VI, section 6 of the California Constitution.  SHEAR DEVELOPMENT CO., LLC v. CALIFORNIA COASTAL COMMISSION S284378 Opinion of the Court by Guerrero, C. J. In 2017, Shear Development Co., LLC (Shear), applied to the County of San Luis Obispo (County) for a coastal development permit to build single family homes in a developed part of Los Osos, an unincorporated town in the County. The County ultimately granted the permit in 2019. The California Coastal Commission (Commission) appealed the County’s decision to itself and denied the permit in 2020. The Commission concluded that it had appellate jurisdiction because the proposed development was in a sensitive coastal resource area (SCRA) under the County’s local coastal program (LCP) and because there was more than one principal permitted use of the proposed development site under the County’s LCP. Shear filed a petition for a writ of administrative mandate in superior court, arguing that the Commission had no appellate jurisdiction on either basis. The trial court denied the petition, finding for the Commission on the SCRA issue. Shear appealed, and the County, as amicus curiae, agreed with Shear’s positions. The Court of Appeal affirmed the trial court’s judgment. We granted review to decide the standard of review a court should apply when determining whether the Commission’s exercise of appellate jurisdiction over a coastal development permit was proper and, when the Commission and a local government offer conflicting interpretations of an LCP, whether deference is due to either entity’s interpretation. To clarify how 1  SHEAR DEVELOPMENT CO., LLC v. CALIFORNIA COASTAL COMMISSION Opinion of the Court by Guerrero, C. J. these principles should be applied, we further decide whether the proposed development is in an SCRA based on the LCP. After argument, we requested supplemental briefing on the Commission’s alternative asserted basis for jurisdiction; namely, whether the Commission has appellate jurisdiction over a development that is not designated as the only principal permitted use in a county’s LCP. We hold, first, that a court should exercise its independent judgment in determining the Commission’s appellate jurisdiction when that jurisdiction depends primarily on interpretation of an LCP rather than factual matters. An LCP is enacted law, and the independent judgment standard is well established as the standard of review for an agency’s interpretation of the law. Second, where two entities offer incompatible interpretations of a law that both administer, a court should apply the traditional Yamaha factors regarding agency deference to each entity’s interpretation. (See Yamaha Corp. of America v. State Bd. of Equalization (1998) 19 Cal.4th 1, 12–13 (Yamaha).) When the factors do not clearly favor either interpretation, as here, no deference is due to either. Third, the proposed development is not in an SCRA because the LCP does not designate it so. The Commission relies primarily on a single figure in the LCP, captioned “Figure 6-3” (see pt. II.E.1., p