In General Development Co. v. City of Santa Maria, published January 25, 2012, the Second District Court of Appeal, Division Six, interpreted Government Code section 65009 (c)(1)(B) -- which requires any action challenging a legislative body's decision on adopting or amending a zoning ordinance to be filed within 90 days of the decision -- to apply to a city council's denial of an application for a zone change. The court affirmed the trial court's decision sustaining the respondent city's demurrer to a petition for writ of administrative mandamus on the ground that it was untimely.

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