California Supreme Court

Cox v. City of Oakland

January 23, 2025

Summary

The court held that a pre-1972 conveyance of contiguous land identified as multiple lots does not create separate legal parcels merely because the deed lists the lots individually. Under the Subdivision Map Act, a conveyance creates a parcel through a division of land only when it places the conveyed portion into separate ownership from the surrounding land. Because Lot 18 was always conveyed with contiguous property, it was not a parcel entitled to the conclusive presumption of legality, and the judgment of the Court of Appeal was reversed.