Sunday, April 14, 2013

Williamson County Regional Planning Comm. v. Hamilton Bank of Johnson City case brief

Williamson County Regional Planning Comm. v. Hamilton Bank of Johnson City case brief summary
473 U.S. 172

CASE SYNOPSIS:
Petitioner commission and staff sought certiorari to review a judgment of the United States Court of Appeals for the Sixth Circuit, which reinstated an award of damages as just compensation in respondent bank's suit claiming that application of zoning laws and regulations to respondent's residential subdivision amounted to a taking under the Just Compensation Clause of the Fifth Amendment.

OVERVIEW: Respondent bank sued petitioner commission and staff, claiming that application of zoning laws to respondent's residential subdivision was a taking under the Fifth Amendment's Just Compensation Clause. After an appellate court reinstated damages as just compensation, petitioner sought certiorari.

HOLDING:
The Court concluded that respondent's claim was not ripe because respondent did not obtain a final decision for the application of zoning ordinance and subdivision regulations to the property, nor used state procedures for obtaining just compensation.

ANALYSIS:
Respondent's claim was premature as both a deprivation of property without due process under the Fourteenth Amendment and a taking under the Just Compensation Clause of the Fifth Amendment. There was no evidence that respondent applied to an appellate board for variances from the zoning ordinance. A second reason the taking claim was not yet ripe was that respondent did not seek compensation through the procedures the state provided. If a state provided an adequate procedure for seeking just compensation, respondent could not claim violation of the just compensation clause until it used the procedure and was denied just compensation.

OUTCOME: The Court reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with the Court's opinion.

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