City of Monterey v. Del Monte Dunes at Monterey, Ltd.
Headline: Court affirms jury verdict for landowners, allowing juries to decide certain regulatory takings claims and making it easier for property owners to have juries assess local zoning denials when compensation remedies are lacking.
Holding: The Court affirmed the judgment, holding that Del Monte Dunes could have a jury decide its §1983 regulatory takings claim and that juries may resolve whether a city's denial deprived all economic use or substantially advanced public purposes.
- Allows juries to decide liability in some regulatory takings claims under §1983.
- Gives landowners a jury trial when state compensation remedies are inadequate.
- Limits decision to §1983 suits; does not broadly erase zoning authority.
Summary
Background
A private developer sought to build housing on a 37.6-acre oceanfront parcel at the edge of Monterey. Over five years the city repeatedly rejected smaller and smaller plans, imposing conditions and then denying the final 190-unit proposal. The land had environmental issues, including nonnative “ice plant” and potential habitat for the Smith’s Blue Butterfly; the State later bought the land during the litigation. The developer sued the city under 42 U.S.C. §1983, claiming the denial was an uncompensated regulatory taking and that the city had no adequate state remedy.
Reasoning
The Supreme Court addressed whether the takings liability issues could properly be decided by a jury. The Court held that a §1983 suit seeking money damages is an action at law and that the Seventh Amendment preserves a jury right for such suits. The Court explained that questions about whether the owner was deprived of all economically viable use and whether the city’s denial substantially advanced legitimate public purposes were, on these facts, fact-bound and suitable for jury resolution. The Court also rejected extending Dolan’s “rough proportionality” test beyond exaction cases and emphasized that the ruling was narrow and fact-specific.
Real world impact
The decision lets landowners in similar §1983 cases have juries decide key factual takings questions when state compensation procedures are inadequate. It does not invalidate ordinary zoning laws or broadly prevent judges from resolving legal questions about policy. The ruling is limited to the particular procedural posture and does not announce a new, general rule displacing normal judicial review.
Dissents or concurrances
Justice Scalia joined most of the opinion and stressed uniform treatment of §1983 jury rights; Justice Souter (joined by three Justices) disagreed in part, arguing inverse-condemnation claims are unlike ordinary torts and need not carry a jury right.
Opinions in this case:
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