Case No. 17-647 | 3d Cir.
Preview by Alex Davis
In Williamson County Regional Planning Commission v. Hamilton Bank, 473 U.S. 172 (1985), the Supreme Court held that a property owner seeking just compensation from a local government must exhaust state court procedures before bringing a takings claim in federal court. In this case, Petitioner urges the Court to reconsider that holding.
Knick v. Township of Scott arises from a local ordinance regulating cemeteries. The ordinance requires property owners to allow public access to private cemeteries during daytime hours. The township issued a notice of violation to the petitioner and ordered that she open her land to the public. The petitioner sought injunctive relief in federal court, alleging that the ordinance violated the Fifth and Fourteenth Amendments. The district court dismissed the claim because The petitioner failed to exhaust state court procedures before filing in federal court. The Third Circuit affirmed.
The petitioner argues that the Court should overturn Williamson County’s ripeness doctrine for two reasons: First, the petitioner asserts that just compensation suits in state court trigger issue and claim preclusion, which bar federal courts from ruling on any related takings claims. Second, the petitioner argues that even if a property owner files in state court, the government can remove the action to federal court, where the action must either be dismissed or remanded to state court under the ripeness doctrine. Petitioner’s Brief on the Merits at 11–14, Knick v. Township of Scott, No. 17-647 (U.S. filed May 29, 2018). Thus, the petitioner argues that the current ripeness doctrine is unworkable and “ban[s] property owners from asserting their federal constitutional rights in federal court.” Id. at 24.
The township presents a narrower interpretation of Williamson County. It argues that the decision provides a reasonable interpretation of 42 U.S.C. § 1983 (2018), which allows plaintiffs to sue in federal court if they are constitutionally harmed. See Brief for Respondents at 2, 7, Knick v. Township of Scott, No. 17-647 (U.S. filed July 30, 2018). The township argues that since the petitioner, like the property owner in Williamson County, had an opportunity to seek just compensation through state court procedures, she suffered no constitutional harm that could authorize a § 1983 suit. Id. at 19–20.
The government has filed an amicus brief in this case. It argues, like the township, that Williamson County merely provides an interpretation of § 1983. Like the petitioner, however, it also argues that Williamson County is unworkable in practice because of claim and issue preclusion. It asks the Court to either (1) clarify that under Williamson County local property owners can file suit in federal court under federal question jurisdiction; or (2) reconsider Williamson County’s interpretation of § 1983 and allow local property owners to bring suit under the statute without exhausting state court procedures. Brief for the United States as Amicus Curiae in Support of Vacatur and Remand at 6–8, Knick v. Township of Scott, No. 17-647 (U.S. filed July 30, 2018).
Thus, Knick gives the Court an opportunity to clarify complex precedent. The case could also provide insight into the Court’s willingness to overturn settled precedent.