Under the Subdivision Map Act, the creation of legal parcels prior to 1972 requires more than a deed referencing multiple lots—only a conveyance that separates a portion of land from contiguous property creates a new legal parcel. Cox v. City of Oakland, 17 Cal.5th 362 (2025).

The Supreme Court of California held that implied easements may preclude most practical uses by the owner of the property subject to the easement if there is clear evidence of intent to create such an easement at the time of the property division. Romero v. Shih, 15 Cal. 5th 680 (2024).

The First District Court of Appeal held that a single deed conveying four or fewer contiguous lots can qualify for a presumption of legality under section 66412.6(a) of the Subdivision Map Act so long as the lots are separately described (including by reference to an antiquated subdivision map) and all other requirements of section 66412.6(a) are satisfied.

The Fourth District Court of Appeal held that California courts do not have jurisdiction to adjudicate claims involving objections to regional housing needs assessment (RHNA) allocations. City of Coronado v. San Diego Association of Governments, 80 Cal. App. 5th 21 (2022).