California and Hawaii enact some of the first agency disclosure laws.  At least 47 states now require some form of agency disclosure.

In Nollan v. California Coastal Commission, the US Supreme Court concludes that the Commission can’t require property owners to provide public access to beaches (an easement) in return for private property permit approvals.

The US Supreme Court, in First English Evangelical Church v. County of Los Angeles, decides that the temporary, as opposed to permanent, taking of property without compensation is unconstitutional.

Prudential forms a real estate division.