San Remo Hotel, L. P. v. City & County of San Francisco
Headline: Court refused to create an exception to the full faith and credit law, upholding preclusion and barring a federal forum for takings claims litigated and decided in state court.
Holding: The Court held that federal courts must give preclusive effect to state-court takings judgments under 28 U.S.C. §1738 and will not carve out an exception to allow federal relitigation of such claims.
- State-court takings judgments can block relitigation of identical federal claims.
- Property owners forced into state proceedings may lose a second federal forum.
- Affirms federal courts must respect state final judgments under 28 U.S.C. §1738.
Summary
Background
The owners of the San Remo Hotel in San Francisco sued after the city imposed a $567,000 conversion fee under a hotel conversion ordinance. They first sought state review, then filed federal takings claims, and a federal court abstained on one facial challenge while they pursued state proceedings. California courts rejected their state-law takings claims, and when the owners returned to federal court they asked judges to ignore the federal full faith and credit law (28 U.S.C. §1738) so their federal takings claims would not be barred by issue preclusion.
Reasoning
The Court addressed whether federal courts must create an exception to §1738 for Takings Clause claims and refused. It explained that England-style reservations do not allow relitigation of the same federal issues after a party broadens state litigation, and that Williamson County ripeness rules do not eliminate the ordinary preclusive effect of valid state-court judgments. The Court rejected the Second Circuit’s contrary view in Santini and noted that Congress has not signaled any intent to exempt takings claims from §1738.
Real world impact
Property owners who are required to seek compensation or other state relief before federal takings suits should expect state-court judgments to block re-litigation of identical federal issues. The ruling preserves comity and finality between state and federal courts and limits the availability of a second federal forum for claims decided in state court.
Dissents or concurrances
Chief Justice Rehnquist, joined by three Justices, concurred in the judgment but urged reconsideration of Williamson County’s state-litigation requirement for takings claims.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?