Under the modern day Subdivision Map Act, a "parcel" is "created" when the map depicting the lot is recorded (Gov. Code § 66412.7). An issue bubbling for some time in the Map Act world was whether or not that modern-day rule applied to maps recorded in the late 1800s and early 1900s. As we discussed in previous Alerts, California courts first addressed this issue by ruling that any recorded maps before 1893 (the year the Map Act was first enacted) could not create parcels without a separate conveyance. (Gardner v. County of Sonoma, 29 Cal.4th 990 (2003).)

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