Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City
United States Supreme Court
473 U.S. 172 (1985)
Hamilton Bank (plaintiff) acquired a Tennessee subdivision property by foreclosure amid a long dispute over whether a 1973 or 1977 density ordinance governed it. When Hamilton resubmitted subdivision plats, the Williamson County Planning Commission (defendant) rejected them for reasons drawn from both ordinances. Neither Hamilton nor the prior owner sought a variance, and Hamilton never sought compensation through state procedures. Hamilton sued in federal court claiming a regulatory taking; a jury awarded $350,000, but the trial court entered judgment for the Commission, finding only a temporary deprivation. The court of appeals reversed, and the Supreme Court granted certiorari.
Whether a regulatory-takings claim is ripe when the government has not reached a final decision on how its regulations apply to the property and the owner has not sought compensation through available state procedures.