In a decision unlikely to be the final word on the subject, the First District Court of Appeal has ruled that the laws governing subdivision maps in 1915 did not regulate the design and improvement of subdivisions, as required by the current grandfather clause in Government Code section 66499.30(d); as a result, the court held that the proper recording of a subdivision map in 1915 in compliance with the applicable law at the time ? without any subsequent independent conveyances of the parcels shown on the face of the map ? did not create legal parcels (Witt Home Ranch v. County of Sonoma (2008) 165 Cal.App.4th 543).

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