San Remo Hotel, L.P. v. City and County of San Francisco
United States Supreme Court
545 U.S. 323, 125 S. Ct. 2491, 162 L. Ed. 2d 315 (2005)
- Written by Tanya Munson, JD
Facts
Robert and Thomas Field (the owners) (plaintiffs) owned and operated the San Remo Hotel L.P. (the hotel) in San Francisco, California (the city) (defendant). In 1981, the city enacted the San Francisco Residential Hotel Unit Conversion and Demolition Ordinance (HCO) to regulate future conversions. Under the HCO, a hotel owner could only convert residential units into tourist units by obtaining a conversion permit. In 1990, the owners applied to convert all the hotel rooms into tourist-use rooms. The city planning commission granted the application but imposed several conditions including a $567,000 “in lieu” fee. The owners appealed, arguing that the HCO requirement was an unconstitutional taking in violation of the Takings Clause of the Fifth Amendment. The federal court found that the owners’ facial takings claim was untimely, and the as-applied takings claim was unripe. The federal court of appeals found that the Takings Clause claim was unripe because the owners had not pursued an inverse-condemnation action in state court. The federal court of appeals stated that to retain a right to raise their federal claim in federal court, the owners must reserve the action in state court. The owners filed their claims in state court. The case made its way to the California Supreme Court, which analyzed the owners’ takings claims under both state and federal law. The state supreme court upheld the HCO and reinstated the trial court’s dismissal of the owners’ complaint. The owners subsequently filed an amended complaint in federal district court. The federal district court found that the owners’ complaint was barred by the rule of issue preclusion. The owners appealed, arguing that general preclusion principles should be set aside when a case is forced into state court involuntarily. The federal court of appeals affirmed the judgment of the district court. The Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Stevens, J.)
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