In 2017, a California farming family began fighting a rule tying a second home on 267 acres to future commercial farming; nine years later, the US Supreme Court declined to hear the appeal
A California family’s attempt to build a second home on its 267-acre coastal property has ended at the nation’s highest court, after the US Supreme Court declined to hear the family’s appeal in June 2026. The dispute began in 2017, when Willie Benedetti filed a lawsuit challenging Marin County’s land-use restrictions; the county later adopted amended rules requiring owners seeking certain additional homes on agricultural coastal land to record a covenant tied to agricultural use. According to the Pacific Legal Foundation, which represents the Benedetti family, the rule improperly conditions residential development on a landowner’s continued involvement in farming. The Supreme Court denied the family’s petition on June 29, 2026.
A 267-acre family property
The property at the centre of the dispute is in Valley Ford, in Marin County, California. Willie Benedetti spent decades farming the 267 acres and operated agricultural businesses connected to the property. According to the court record, the land consists of two contiguous parcels within the county’s coastal agricultural production zoning area. One of the parcels already had a residence where Willie lived with his son Arron.Willie also intended to build another home on the property for his other son, Arthur. However, the family’s plans became complicated after Marin County adopted an amended local coastal program and later implementing ordinances that changed the conditions attached to additional residential development on agricultural land. Willie filed the initial lawsuit in July 2017. He died in 2018, before the litigation was resolved, and his sons Arron and Arthur continued the case.
What the county’s rule required
The county’s amended rules allow certain additional residential units on coastal agricultural land, but they require the property owner to record a restrictive covenant benefiting the county. Under the provision, the owner of the new agricultural dwelling must remain “actively and directly engaged” in agricultural use of the property. The county defines that requirement as either being directly involved in commercial agricultural production or maintaining a lease with a bona fide commercial agricultural producer. The covenant also runs with the land. That means the restriction is not limited to the person who initially receives permission to build. It can bind future owners as well.The county’s stated objective is to protect agricultural land and prevent residential development and residential property values from gradually displacing agriculture in the coastal zone. The amended rules also recognise that housing can be necessary to support agricultural operations. They therefore allow agricultural dwelling units under specified conditions, including a farmhouse, an intergenerational home and agricultural worker housing.
Why the Benedettis challenged it
The Benedettis argued that the county’s requirement went beyond ordinary land-use regulation. Arron and Arthur are plumbers rather than farmers, and the court record states that neither is engaged in the day-to-day operation of the family’s agricultural companies. The family therefore challenged the requirement that a person seeking to build the additional home either personally participate in commercial agriculture or lease the property to a commercial agricultural producer.Their lawsuit raised constitutional arguments involving property rights, due process and the Supreme Court’s decisions in Nollan v. California Coastal Commission and Dolan v. City of Tigard. Those cases concern the constitutional limits on conditions that governments place on development approvals. The Benedettis argued that the agricultural covenant did not have the required connection and proportionality to the impacts of constructing another residence. They also argued that the condition effectively interfered with their freedom to choose their occupation.
California courts rejected the challenge
The Marin County Superior Court rejected the family’s claims. The Benedettis then appealed. In August 2025, California’s First District Court of Appeal affirmed the lower court’s judgment, although it disagreed with part of the trial court’s reasoning. The appellate court held that the Benedettis could bring a facial challenge under Nollan and Dolan. However, it concluded that the county’s agricultural covenant satisfied the constitutional requirements.The court found a sufficient connection between the condition and Marin County’s interest in maintaining agriculture in the coastal zone. In its analysis, allowing additional residential development without an agricultural requirement could increase the residential value of farmland and make agricultural uses less economically viable. The court also concluded that the condition was proportionate because it tied additional residential development to the continued agricultural use of the same property.
The occupation argument
The Benedettis separately argued that the covenant effectively forced property owners into a particular occupation. The appeals court rejected that argument as well. The court relied on an earlier California Supreme Court decision, Nash v. City of Santa Monica, which held that property regulations can limit how owners use their property without necessarily triggering strict constitutional scrutiny merely because those restrictions affect the owner’s occupational choices.The appeals court noted that the Marin County rule does not require an owner to personally perform all agricultural work. A landowner can lease the property to a commercial agricultural producer and satisfy the requirement that way. The owner can also sell the property. Based on that reasoning, the court applied rational-basis review and concluded that the agricultural requirement was reasonably related to the county’s goal of preserving agriculture.
The case reaches the Supreme Court
After losing in California’s courts, the Benedettis asked the US Supreme Court to intervene. Their petition raised questions about whether the government can condition permission to build a home on a person’s commitment to a government-preferred occupation and whether such a condition violates constitutional protections. The Supreme Court docket shows that the petition was filed on April 24, 2026. The case was distributed for the justices’ June 25 conference. On June 29, 2026, the Supreme Court denied the petition. That denial means the California Court of Appeal’s 2025 judgment remains in place. It does not constitute a Supreme Court ruling on the underlying constitutional questions.For the Benedetti family, the litigation that began with a planned second home on a long-held agricultural property has therefore reached its current endpoint without a Supreme Court review. The county’s requirement remains enforceable under the judgment that the family challenged, leaving the 267-acre property at the centre of a dispute over how far local governments can go in tying residential development to the continued agricultural use of private land.
