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Abstract
The decision of California's 2nd District Court of Appeal in First English makes me want to say, “We told you so.” Just about every experienced land use lawyer I know correctly predicted that, on remand, the California courts would hold that there was no taking because some economic uses, for example, tent camping, could be carried on even during the moratorium. The Court of Appeal, again as predicted by many, also held that the interim ordinance was reasonable in its purpose, duration, and scope.