An initiative measure that required new development to mitigate not only its individual traffic impacts but also cumulative impacts of other projects on traffic levels of service violated the rough-proportionality standard of Nollan and Dolan and was therefore unconstitutional.

Multiple applications for a development project are not required where the first permit denial makes clear that no development of the property would be allowed under any circumstance. Felkay v. City of Santa Barbara, No.

Three months ago, the Fourth District Court of Appeal upheld a Coastal Commission fine of $1 million on homeowners who performed major reconstruction on their Malibu home without obtaining coastal permits and refused to halt construction after notification of the violation by Commission staff.

Another court of appeal has held that local special taxes adopted by a citizen-sponsored initiative do not require two-thirds voter approval.  Howard Jarvis Taxpayers Association v.