We know you are really busy, takings mavens, you don't have to read all 47 pages of the California Court of Appeal's opinion in Martis Camp Community Ass'n v. County of Placer, No. C087759 (Aug. 17, 2020). Instead, you can jump to page 44 for the good stuff.
Short story: the court held that the plaintiff -- a community association for a residential subdivision -- did not state a valid claim for inverse condemnation for a taking of access rights because it did not own property actually abutting a public road. The court acknowledged that abutting landowners have a property right to access the streets, a "property right in the nature of a private easement in the street upon which the property abuts." Slip op. at 44.
But the Association did not actually own any of the parcels abutting the street in question. Instead, the Association alleged that it possesses a "nonexclusive easement for ingress and egress over all the subdivision's roads." Slip op. at 45. This wasn't enough of an interest to give the Association any rights to damages:
The abandonment of Mill Site Road did not interfere with the Martis Camp Homeowners’ easement over the subdivision’s streets or render their homesites inaccessible. Plaintiffs have not cited any authority to support their novel legal theory that nonabutting landowners may claim damages for interference with an abutting landowner’s separate access rights merely because they have been granted a nonexclusive easement over that property.
Slip op. at 46-47.
Martis Camp Community Ass'n v. County of Placer, No. C087759 (Cal. Ct. App. Aug. 17, 2020)
