Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City
Headline: Local zoning denial is not yet a compensable taking; Court limited immediate damages and sent the landowner back to local permits and state compensation procedures before money can be awarded.
Holding: The Court held that the landowner’s claim for money is not ripe because local officials had not made a final decision and the owner must pursue variances and state compensation procedures first.
- Requires owners to seek local variances before suing for compensation in federal court.
- Means temporary regulatory losses may not produce quick federal damage awards.
- Pushes more compensation disputes into state compensation procedures.
Summary
Background
A bank owned land it planned to develop as a large residential subdivision called Temple Hills. The county planning commission approved an initial plan in 1973 but later rejected renewed plats, citing eight problems such as density calculations, steep slopes, road grades, cul-de-sac length, and inadequate fire protection. After the commission’s 1981 disapproval, a jury awarded the bank $350,000 for a temporary “taking,” but lower and appellate courts disputed whether money was owed.
Reasoning
The Court held the bank’s claim was premature because county officials had not made a final, definite decision about how the rules would apply. The bank had not sought variances from the commission or the county appeals board and had not used Tennessee’s procedures for getting compensation (an inverse-condemnation action). Because the economic harm and interference with the bank’s development expectations could change if variances or state procedures were used, a federal taking claim could not be decided yet. The Court also declined to decide whether such regulation should be treated as a “taking” or a due-process problem requiring compensation.
Real world impact
The ruling sends landowners back to local permitting and to state compensation remedies before seeking federal money damages. It means courts should wait for final administrative decisions so they can accurately measure economic loss. The opinion leaves open whether temporary regulatory losses ever require money in all cases.
Dissents or concurrances
Justices Brennan and Stevens joined or wrote opinions noting different views: Brennan favored compensation for temporary takings but agreed the claim was premature; Stevens emphasized procedural fairness and thought the damages award could not stand given the jury’s findings about due process.
Opinions in this case:
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