A grading permit for a nursery in Huntington Beach did not violate a six-year-old conditional use permit and was not subject to environmental review, the Fourth District Court of Appeal has ruled.

Voters in two small towns rejected development during special elections in April. Voters in the San Gabriel Valley city of Sierra Madre approved a referendum that requires projects of a certain size in downtown to go before voters. Meanwhile, voters in the Solano County city of Dixon rejected a proposed horse track and entertainment facility.

Both elections were close, and the land use battles in both cities appear far from over. The balloting may provide cautionary tales for planners, as both elections occurred after lengthy planning processes.