Facts
- A developer obtained preliminary approval in 1973 to develop a 676-acre residential subdivision under then-existing county “cluster” zoning and implementing regulations.
- In 1977, the county reduced allowable density by amending its zoning ordinance; for a period, county officials continued applying the 1973 rules to the tract.
- In 1979, the planning commission determined that further development must comply with current, more restrictive regulations and began disapproving plats for noncompliance, including density limits.
- Hamilton Bank acquired the tract through foreclosure and submitted a revised preliminary plat; the commission rejected it on multiple grounds tied to the newer rules.
- A county board of zoning appeals later concluded the 1973 regulations controlled, but the commission still refused to approve the revised plat.
- The bank sued in federal court under 42 U.S.C. § 1983, alleging (1) a taking without just compensation and (2) violations of procedural and substantive due process.
- A jury awarded damages for a “temporary taking,” finding denial of “economically viable” use; the district court ordered the commission to apply the 1973 rules but set aside the damages verdict as a matter of law.
- The court of appeals reinstated the damages verdict, and the Supreme Court granted review.
Issues
- Whether a § 1983 claim alleging a regulatory taking without just compensation was ripe for federal adjudication.
- Whether procedural and substantive due process claims based on the same land-use dispute were ripe for federal adjudication.
Decision
- The Supreme Court reversed and remanded, holding the federal takings claim was not ripe.
- The claim was premature because the bank had not obtained a final decision on how the regulations applied to the property.
- The claim was also premature because the bank had not sought compensation through Tennessee’s available procedures for obtaining just compensation.
- The due process claims were likewise unripe given the absence of a final land-use determination and the availability of state processes to address or remedy the alleged harms.
Legal Principles
- A regulatory takings claim is generally not ripe until the relevant agency has issued a final, definitive decision applying the regulations to the property.
- Without a final decision, a court cannot assess the regulation’s economic impact or interference with reasonable investment-backed expectations.
- Because the Takings Clause prohibits takings without just compensation, no federal just-compensation violation is complete while the state provides a reasonable, certain, and adequate mechanism for obtaining compensation that has not been used and denied.
- Related due process challenges to land-use decisions are generally premature when the scope of permitted development remains unsettled and state procedures exist to address the asserted injury.
Conclusion
The Court held that the bank’s federal takings and due process claims were premature because there was no final administrative determination of permissible development and the bank had not pursued state procedures to obtain just compensation, requiring reversal of the judgment allowing federal damages to stand.