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Abstract
The California Supreme Court has been reinforcing its reputation as preservationist in land development and environmental control controversies for over a decade.1 Many of these cases led to the court's national reputation as one that made significant decisions.2 The reputation is probably undeserved. The decisions were mostly noteworthy because they were so biased against development interests. As distinguished from most state supreme courts, the California high court always found against the developer.3 To knowledgeable observers, then, the court's decisions had a ho-hum predictability about them.