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Abstract
| Argument: |
Wednesday, October 7, 1998
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| Decision: |
Monday, May 24, 1999 |
| Issues: |
Due Process, Takings Clause |
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Advocates
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Facts of the Case
Del Monte Dunes sought to develop property it owned within the jurisdiction of the city of Monterey. Monterey continuously denied Del Monte Dunes' proposals to develop the property. Each rejection was followed by stricter and more rigorous demands for a smaller, less intrusive development. After years of rejection, Del Monte Dunes decided Monterey would not allow development under any circumstances. Del Monte Dunes sued the city in federal court under 42 USC Section 1983, alleging that the denial of their final proposal was a violation of the Due Process and Equal Protection clauses of the Fourteenth Amendment. Moreover, Del Monte Dunes claimed, the continuous demands constituted regulatory abuse. The District Court submitted Del Monte Dunes case to the jury. The judge instructed the jury to find for Del Monte Dunes if the jurors found Del Monte Dunes had been denied every economically viable use for its property or if the city's decision to reject the development did not directly advance a legitimate public purpose. The jury found for Del Monte Dunes on the equal protection and abuse claims, and it awarded monetary damages. The city prevailed on the due process claim. The Court of Appeals affirmed the rulings despite the city of Monterey's objection to the use of a jury in government land-use regulation cases. It found no errors in the use of the jury or the jury's decision.
Question
Do plaintiffs have a right to a jury trial over land-use regulations when they allege constitutional violations under 42 USC Section 1983?
Conclusion
Yes. The Court held, in an opinion authored by Justice Anthony M. Kennedy, that property owners who file a Section 1983 civil rights suit seeking compensation for an alleged taking of their property can have a jury trial in some circumstances. "[T]he disputed questions were whether the government had denied a constitutional right outside the bounds of its authority, and, if so, the extent of any resulting damages." Justice Kennedy then added: "These were questions for the jury."
