Cal. Codes » Government Code / TITLE 7. PLANNING AND LAND USE / DIVISION 2. SUBDIVISIONS / CHAPTER 7. Enforcement and Judicial Review / ARTICLE 3. Judicial Review
California Codes

Cal. Government Code § 66499.37 (2026)

Judicial Review

✓ leginfo export of Sept. 26, 2026 (applied Oct. 1, 2026)
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Any action or proceeding to attack, review, set aside, void, or annul the decision of an advisory agency, appeal board, or legislative body concerning a subdivision, or of any of the proceedings, acts, or determinations taken, done, or made prior to the decision, or to determine the reasonableness, legality, or validity of any condition attached thereto, including, but not limited to, the approval of a tentative map or final map, shall not be maintained by any person unless the action or proceeding is commenced and service of summons effected within 90 days after the date of the decision. Thereafter all persons are barred from any action or proceeding or any defense of invalidity or unreasonableness of the decision or of the proceedings, acts, or determinations. The proceeding shall take precedence over all matters of the calendar of the court except criminal, probate, eminent domain, forcible entry, and unlawful detainer proceedings.

Notes of Decisions
Cited in 26 cases (4 in the last 5 years), 1978–2023 · leading case: Hensler v. City of Glendale, 876 P.2d 1043 (Cal. 1994).
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Hensler v. City of Glendale, 876 P.2d 1043 (Cal. 1994). · cites it 2× “10 By contrast, if the challenge is to the application of the regulation to a specific piece of property, the statute of limitations for initiating a judicial challenge to the administrative action runs from the date of the final adjudicatory administrative decision.”
California Bldg. Indus. Ass'n v. City of San Jose, 351 P.3d 974 (Cal. 2015). · cites it 2× “One of the potentially applicable statutes of limitation — Government Code section 66499.37, a part of the Subdivision Map Act — was a general statute of limitations requiring lawsuits challenging the validity of conditions attached to the approval of a tentative or final map to…”
MAGINN v. City of Glendale, 72 Cal. App. 4th 1102 (Cal. Ct. App. 1999). · cites it 4× “Government Code section 66499.37 provides that any action or proceeding to review a decision concerning a subdivision must be “commenced and service of summons effected within 90 days after the date of such decision.”
Lacher v. Superior Court, 230 Cal. App. 3d 1038 (Cal. Ct. App. 1991). · cites it 2× “) Any action to challenge the environmental approvals for a development project must be brought within the time periods set forth in Public Resources Code section 21167, and the hearing on such a challenge must be given preference "to the end that all such actions shall be…”
Friends of Shingle Springs Interchange, Inc. v. Cnty. of El Dorado, 200 Cal. App. 4th 1470 (Cal. Ct. App. 2011). “37 provides: “Any action or proceeding to attack, review, set aside, void, or annul the decision of an advisory agency, appeal board, or legislative body concerning a subdivision, or of any of the proceedings, acts, or determinations taken, done, or made prior to the decision,…”
Linda Vista Vill. San Diego Homeowners Ass'n v. Tecolote Investors, LLC, 234 Cal. App. 4th 166 (Cal. Ct. App. 2015). “) We view this complaint as essentially alleging that public property was illegally transferred, in violation of “binding” charter provisions. Such claims about ongoing public entitlement to use of contested property can be exempted from the application of statutes of…”
City of Saratoga v. Hinz, 115 Cal. App. 4th 1202 (Cal. Ct. App. 2004). “37 provides for a 90-day limitations period on “[a]ny action or proceeding to attack, review, set aside, void or annul the decision of an advisory agency, appeal board or legislative body concerning a subdivision, .”
Templeton Action Comm. v. Cnty. of San Luis Obispo, 228 Cal. App. 4th 427 (Cal. Ct. App. 2014). · cites it 2× “Government Code section 66499.37 requires a party seeking to attack an appeal board’s or legislative body’s decision concerning a subdivision to commence a proceeding and serve the summons within 90 days of the decision.”
Timberidge Enter., Inc. v. City of Santa Rosa, 86 Cal. App. 3d 873 (Cal. Ct. App. 1978). “Among the defenses raised by the City’s answer, and thus by the District’s complaint in intervention, was the bar of the statute of limitations of Government Code section 66499.37 found in the Subdivision Map Act under which plaintiffs’ subdivision maps were approved.”
Torrey Hills Cmty. Coalition v. City of San Diego, 186 Cal. App. 4th 429 (Cal. Ct. App. 2010). · cites it 2× “On April 17, Torrey Hills filed a document entitled “Notice of Request for Hearing” (some capitalization omitted), which notified the City and Westbrook that on February 5, 2009, Torrey Hills’s counsel had orally requested a hearing date from the court clerk on the writ…”
Uniwill L.P. v. City of Los Angeles, 124 Cal. App. 4th 537 (Cal. Ct. App. 2004). “” (Gov. Code, § 66499.37.) 2 Los Angeles Municipal Code section 17.”
Wal-Mart Stores, Inc. v. City of Turlock, 483 F. Supp. 2d 987 (E.D. Cal. 2006). “The City claims Wal-Mart cannot assert an as-applied Commerce Clause challenge to the Ordinance under Section 1983, and consequently any as-applied Commerce Clause challenge is barred by California Government Code Section 66499.”
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