RECENT CALIFORNIA DECISIONS

October 2002

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Court of Appeal: Open Space District which Made a Conveyance of Open Space Lands under the Spectre of Eminent Domain Does Not Require Voter or Legislative Approval
Johnston v. Sonoma County Agricultural Preservation and Open Space District

On July 31, 2002, the First District Court of Appeal held that a decision of the Sonoma County Agricultural Preservation and Open Space District, involving the involuntary conveyance of a utility easement, was governed by eminent domain statutes, and therefore did not require voter or legislative approval.