When the California Coastal Commission's certification of the County of Los Angeles' local coastal program imposed a complete ban on the establishment of all future vineyards in the Santa Monica Mountains, did it deprive Petitioners (as property owners) of rights secured by the United States Constitution?

QUESTIONS PRESENTED 1. When the California Coastal Commission’s certification of the County of Los Angeles’ local coastal program imposed a complete ban on the establishment of all future vineyards in the Santa Monica Mountains, did it deprive Petitioners (as property owners) of rights secured by the United States Constitution? For example: a. Were Petitioners’ rights to procedural due process under the Fourteenth Amendment to the United States Constitution violated when the California Coastal Commission gave 24-hours’ notice of its 176page modifications to the Local Coastal Program, switching from a complete ban of all future crop-based agriculture to a ban on the establishment of all future vineyards in the Santa Monica Mountains in perpetuity? b. Were Petitioners’ rights to substantive and procedural due process also violated by the California Coastal Commission’s application and interpretation of state statutes and regulations governing “amendment of a certified local coastal program,” where no certified local coastal program existed for the Santa Monica Mountains and by calling it an “amendment,” the Commission could avoid a mandated “substantial issue” determination and a separate public hearing? ii QUESTIONS PRESENTED — Continued c. Does the Constitution protect against zoning laws that are unduly oppressive, arbitrary and unreasonable as applied and interpreted by the California Coastal Commission to destroy a fundamental attribute of property ownership — the pursuit of a lawful business enterprise on private property? This Court’s cases suggest that the answer is “yes” to each of these questions.