Facts
- Del Monte Dunes owned a 37.6-acre oceanfront parcel in Monterey, California, zoned for multifamily residential use.
- Over several years, the City denied five successive development applications for the parcel, each time imposing more stringent conditions.
- Del Monte Dunes concluded the City would not allow any economically viable development and sued under 42 U.S.C. § 1983.
- The suit alleged a regulatory taking and related constitutional violations arising from repeated denials without compensation or an adequate post-deprivation remedy.
- The district court tried the case to a jury and instructed that liability could be found if the jury concluded either (a) the City denied all economically viable use or (b) the final denial did not substantially advance a legitimate public purpose.
- The jury returned a verdict for Del Monte Dunes and awarded damages; the City prevailed on a separate due process claim.
- The Ninth Circuit affirmed, including the determination that the case was properly submitted to a jury; the City sought Supreme Court review.
Issues
- Whether the Seventh Amendment permits a jury trial on liability and damages in a § 1983 action seeking money damages for an alleged regulatory taking in these circumstances.
- Whether the case was improperly submitted to the jury because the liability standard was erroneous, including references to Dolan’s “rough proportionality” and the “substantially advances” formulation.
- Whether allowing a jury to assess whether a land-use denial substantially advanced legitimate public purposes improperly intrudes on municipal land-use decisionmaking.
Decision
- The Supreme Court affirmed the judgment for Del Monte Dunes.
- The Court held that the § 1983 action for compensation, as tried, sought legal relief (money damages) for an alleged past wrong and was properly decided by a jury on disputed questions of liability and damages.
- The Court treated Dolan’s “rough proportionality” standard as inapposite and, in any event, irrelevant because the jury instructions did not require proportionality findings.
- The Court rejected the City’s characterization of the decision as authorizing broad interference with land-use regulation, construing the affirmance as tied to the specific record of repeated denials and escalating demands.
Legal Principles
- When a § 1983 claim is framed as an action at law seeking money damages for an alleged constitutional violation, the Seventh Amendment may require a jury determination of disputed factual questions bearing on liability and damages.
- A regulatory-takings claim based on repeated permit denials does not, without more, trigger Dolan’s “rough proportionality” test, which concerns exactions imposed as conditions for permit approval.
- Appellate discussion of inapplicable doctrinal tests does not warrant reversal where the actual jury instructions and verdict rest on other properly submitted factual determinations.
- Fact-specific review of an unusually extreme land-use permitting record does not itself establish a general rule for routine zoning or planning disputes.
Conclusion
The Court upheld a jury verdict awarding damages under § 1983 based on a municipality’s repeated denials of development proposals and held that, on the instructions given, submission of the regulatory-takings theory to a jury was proper, while Dolan’s rough-proportionality standard did not govern the case.