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BISHOP v. HANES
Court of Appeals of California, First District, Division One.
Filed October 27, 2011.


 

 

Most tellingly, MacNair testified that on his second visit in 2009, he observed that part of the acacia stand had been removed, and that the balance had been topped. However, from the perspective of the Bishops' property, there was no change in the obstruction from 2008 because "when you top the acacia, there is almost immediate response of rapid regrowth . . . and so it goes into an active growth phase, and that's what happened. So the density of the grove was not much different in terms of the foliage mass. There were fewer stems, and they had been brought down a bit, but in terms of the view obstruction, it really wasn't effective." He opined that "you can expect a minimum of three to four feet of growth a year from those trees after a topping cut." As for the Monterey pine, it was not as fast-growing as an acacia, but MacNair nevertheless observed that the branches had been growing fairly rapidly below the pruning cut. Substantial evidence supports the view that even with periodic cutting and topping, the Haneses' trees continually grew and obstructed the Bishops' views from at least 2006 to the present, and that the cutting and topping undertaken in response to mediation had not solved the problem. In our view, the trial court did not abuse its discretion in concluding that the trees constituted a continuing nuisance to which the doctrine of res judicata did not apply.

Application of Oakland's Amended View Ordinance to Defendants Does Not Violate Defendants' Substantive or Procedural Due Process Rights.

Defendants argue that application of the amended View Ordinance to them "constitutes an impermissible retroactive application of the law" that "effects a `taking' of the Hanes property." We disagree, because the law, as applied to them, is prospective in application and, even if it were retroactive, it would not constitute a taking or otherwise violate due process, as explained in Echevarrieta, supra, 86 Cal.App.4th 472.
"A statute has retrospective effect when it substantially changes the legal consequences of past events." (Western Security Bank v. Superior Court (1997) 15 Cal.4th 232, 243 (Western).) In this case, the amended ordinance was applied to view obstructions that postdated the 2004 and 2006 amendments: the Bishops did not request reconciliation and mediation under the ordinance until 2007. The fact that existing trees may or may not have obstructed the Bishops' views before 2004 does not mean that the ordinance is retrospective in its application. "A statute does not operate retrospectively simply because its application depends on facts or conditions existing before its enactment." (Ibid.)
Moreover, both amendments were accompanied by clear legislative statements that it was the intent of the City Council to clarify that the View Ordinance always applied throughout Oakland, and to all trees, sprouted or planted. "[A] statute that merely clarifies, rather than changes, existing law does not operate retrospectively even if applied to transactions predating its enactment. . . . Our consideration of the surrounding circumstances can indicate that the Legislature made material changes in statutory language in an effort only to clarify a statute's true meaning. [Citations.] Such a legislative act has no retrospective effect because the true meaning of the statute remains the same. [Citations.] [¶] One such circumstance is when . . . . [¶] `"[T]he amendment was enacted soon after controversies arose as to the interpretation of the original act, . . ."' [¶] Even so, a legislative declaration of an existing statute's meaning is neither binding nor conclusive in construing the statute. Ultimately, the interpretation of a statute is an exercise of the judicial power the Constitution assigns to the courts. [Citations.] Nevertheless, the Legislature's expressed views on the prior import of its statutes are entitled to due consideration, and we cannot disregard them." (Western, supra, 15 Cal.4th 232, 243-244.)
In this case, shortly after the first lawsuit between the parties resulted in a judicial opinion that the View Ordinance only applied to trees planted in certain areas of Oakland, excluding the parties' properties, the City Council amended the statute, admittedly at the Bishops' instigation. In doing so, the City Council expressly stated that its intent was to "clarify that the private right to reconciliation and arbitration established by the View Ordinance applies throughout the City of Oakland; [and] . . . [¶] . . . to clarify that the View Ordinance applies to all trees at issue on the tree owner's property, both those planted by the tree owner as well as trees allowed to sprout as a result of natural regeneration." Although this expression of intent is not binding on us, defendants do not tender any reason why we should refuse to give it credence. In the absence of any such reasons, we see no basis for disregarding the City Council's stated legislative intent.
In any event, even if the amendments changed, rather than clarified the View Ordinance, the City Council's declarations of intent reflected a "purpose to achieve a retrospective change. . . . `[W]e must give effect to this intention unless there is some constitutional objection thereto.'" (Western, supra, 15 Cal.4th at p. 244.)


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