City of Monterey v. Del Monte Dunes at Monterey, Ltd.

Brief Fact Summary.

Plaintiff tried to develop land on Defendant’s land. Defendant denied the building plans. Plaintiff brought suit, and the jury reached a verdict in Defendant’s favor. Plaintiff appealed, and the appellate court held in Plaintiff’s favor. Plaintiff petitioned for certiorari alleging the jury should never have heard the case and the appellate court applied the wrong legal standard.

Synopsis of Rule of Law.

Both, a regulatory taking claim, under 42 U.S.C. § 1983, and an action at law, may be decided by a jury, pursuant to the Seventh Amendment.

Facts.

Plaintiff, Del Monte Dunes at Monterey, Ltd., tried to develop land in the City of Monterey, Defendant. Nonetheless, Defendant continuously rejected Plaintiff’s expansion plans. Plaintiff initiated this action under 42 U.S.C. § 1983 against Defendant. Plaintiff claims that Defendant’s actions constitute a regulatory taking without just compensation or a post-deprivation remedy. After a jury trial, the jury reached a verdict in Defendant’s favor.  Plaintiff appealed, and the appellate court affirmed the jury’s verdict. Thereafter, Plaintiff petitioned the United States Supreme Court for certiorari on the grounds that the claim, regulatory taking without just compensation, should never have been submitted to a jury. Thus, the appellate court applied the wrong legal standard for a regulatory taking liability. Subsequently, the United States Supreme Court granted certiorari to review.

Issue.

Whether both, a regulatory taking claim, under 42 U.S.C. § 1983, and an action at law, may be decided by a jury, pursuant to the Seventh Amendment.

Held.

Yes, both, a regulatory taking claim, under 42 U.S.C. § 1983, and an action at law, may be decided by a jury, pursuant to the Seventh Amendment.

Dissent.

Yes, both, a regulatory taking claim, under 42 U.S.C. § 1983, and an action at law, may be decided by a jury, pursuant to the Seventh Amendment.

Concurrence.

The Seventh Amendment does not provide a statutory right to a jury trial for causes of actions arising under § 1983, nor did Congress intend to create a statutory right under § 1983 itself. Similar to the regulatory taking cause of action is the condemnation proceeding, in which the latter cause of action was tried without a jury.

Discussion.

Both, a regulatory taking claim, under 42 U.S.C. § 1983, and an action at law, may be decided by a jury, pursuant to the Seventh Amendment. 42 U.S.C. § 1983 allows a party, whose federal rights were denied, based on state law, to bring “an action at law, suit in equity, or other proper proceeding for redress.” Nonetheless, the phrase “an action at law,” alone, does not bring the court to the conclusion that the statute provides a right to a jury trial. Instead, the Court must resolve the constitutional issue at hand to determine whether there is a constitutional right. First, the court must determine if the case could have been tried at law or in analogous at law manner when the nation was originally founded.  If yes, the court must further determine if the act of submitting the case to the jury would  “preserve the substance of the common-law right as it existed in 1791.” The phrase “common-law right” under the Seventh Amendment refers to legal actions, not equitable actions. Thus, if the action present did not exist in 1791, there may be a right to a jury trial under the Seventh Amendment if the claim arises out of a tort or legal relief. Generally, regulatory takings liability is deemed a factual question, which is submitted to the jury. However, the determination of whether an owner has lost all his or her economically viable use in the property is question of fact, and if the taking was for a public purpose is a involves a question of both law and fact. In this case, Plaintiff’s regulatory taking claim is basically a tort cause of action. Plaintiff wants to be compensated for being denied its right to just compensation, a constitutional right. Further, causes of action involving just compensation, monetary relief,  are generally viewed as legal claims. Defendant claims that the cause of action is similar to an eminent domain proceeding in which the parties do not have a right to a jury trial. The Court disagrees with Defendant’s assertion because condemnation claims are fundamentally different than § 1983 claims, as the government acknowledges its liability. Therefore, Plaintiff’s regulatory taking claim, involving a question of fact primarily, and was properly submitted to the jury, and the appellate court’s judgment is affirmed.