While there may not be any private beach under CA law, Kholsa actually tried to use a sneaky legal argument to get around that[1]. Essentially, he argued that federal land patent on the property from the 1800s superseded the California Coastal Act. It didn't work, but had it work it would have set a dangerous precedent for any properties that could make a similar claim.
[1] http://www.mercurynews.com/san-mateo-county-times/ci_2614203...