regulatory takings claim (Washington) · Go Syfert
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regulatory takings claim in Washington

11 Washington opinions name it 2 courts 1987–2019 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Keystone Bituminous Coal Assn. v. DeBenedictisgreen
scotus · 1987 · cited in 2 Washington opinions naming this issue, 1987–2019
2 sentences

2019It was thus difficult to determine whether and to what extent substantive due process principles were relevant to the regulatory takings analysis. 13 Yim et al v. City ofSeattle, No. 95813-1 As a result of such confusion, courts were left to determine when a regulation crosses the line into a regulatory taking based on '"essentially ad hoc, factual inquiries.'" Keystone, 480 U.S. at 495 (internal quotation marks omitted) {(yyolmg Kaiser Aetna V.

1987We can uphold the trial court's summary judgment in Orion's favor only if we conclude that no genuine issues of material fact exist concerning the three components of a regulatory takings claim: (1) whether the regulatory regime as applied to Orion's property scheme was insulated from a takings challenge as part of the State's authority to enact health and safety regulations, see Keystone Bituminous Coal Ass'n v. DeBenedictis, ___ U.S. ___, 94 L.Ed.2d 472, 491-93 , 107 S.Ct. 1232 (1987); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726, 733 , 565 P.2d 1162 (1977); (2) whether

12
Penn Central Transportation Co. v. New York Citygreen
scotus · 1978 · cited in 2 Washington opinions naming this issue, 2000–2000
2 sentences

2000Justice Joseph Story wrote: "All the property and vested rights of individuals are subject to such regulations of police as the legislature may establish with a view to protect the community and its several members against such use or employment thereof as would be injurious to society or unjust toward other individuals. " 2 JOSEPH STORY, COMMENTARIES ON THE CONSTITUTION OF THE UNITED STATES § 1954, at 700-01 (5th ed. 1891) (emphasis added) (quoting Commonwealth v. Alger with approval). [15] "Under the `character-of-the-regulation' prong of the regulatory takings analysis, `[a] "taking" may mo

2000“Under the ‘character-of-the-regulation’ prong of the regulatory takings analysis, ‘[a] “taking” may more readily be found when the interference with property can he characterized as a physical invasion by government than when interference arises from some public program adjusting the benefits and burdens of economic life to promote the social good.’ ” Thomas v. Anchorage Equal Rights Comm’n, 165 F.3d 692 , 709 (quoting Penn Cent., 438 U.S. at 124), withdrawn, 192 F.3d 1208 (9th Cir. 1999).

12
Anthony Simmonds, A/K/A Anthony Simmons v. Immigration and Naturalization Servicegreen
ca2 · 2003 · cited in 1 Washington opinions naming this issue, 2018–2018
2 sentences

2018We exercise our discretion to decide this case on the merits, and we affirm summary judgment dismissal of Thun’s regulatory takings claim because there is no genuine issue of material fact and because Thun fails to meet the threshold requirement of a regulatory takings claim. 1 As we discuss in more detail below, prudential ripeness is “a tool that courts may use to enhance the accuracy of their decisions and to avoid becoming embroiled in adjudications that may later turn out to be unnecessary or may require premature examination.” Simmonds v. Immigration & Naturalization Serv., 326 F.3d 351,

2018We exercise our discretion to decide this case on the merits, and we affirm summary judgment dismissal of Thun’s regulatory takings claim because there is no genuine issue of material fact and because Thun fails to meet the threshold requirement of a regulatory takings claim. 1 As we discuss in more detail below, prudential ripeness is “a tool that courts may use to enhance the accuracy of their decisions and to avoid becoming embroiled in adjudications that may later turn out to be unnecessary or may require premature examination.” Simmonds v. Immigration & Naturalization Serv., 326 F.3d 351,

11
Eastern Enterprises v. Apfelgreen
scotus · 1998 · cited in 1 Washington opinions naming this issue, 1998–1998
1 sentence

1998Regarding the propriety of substantive due process as a overall concept, see Eastern Enters., 118 S. Ct. at 2153 (section IV-D of plurality opinion); Lochner v. New York, 198 U.S. 45 , 25 S. Ct. 539 , 49 L.

11
Christianson v. Snohomish Health Districtgreen
wash · 1997 · cited in 1 Washington opinions naming this issue, 1998–1998
1 sentence

1998See generally id. at 667 (Talmadge, J., concurring); Orion Corp. v. State, 109 Wn.2d 621, 646 , 747 P.2d 1062 (noting, without approval, that “commentators have also pointed out that the regulatory takings doctrine and the longstanding substantive due process test seem analytically identical”), cert. denied, 486 U.S. 1022 (1988).

11
Department of Natural Resources v. Thurston Countygreen
wash · 1979 · cited in 1 Washington opinions naming this issue, 1987–1987
2 sentences

1987See, e.g., Department of Natural Resources v. Thurston Cy., 92 Wn.2d 656 , 601 P.2d 494 (1979), cert. denied, 449 U.S. 830 (1980); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726 , 565 P.2d 1162 (1977).

1987See, e.g., Department of Natural Resources v. Thurston Cy., 92 Wn.2d 656 , 601 P.2d 494 (1979), cert. denied, 449 U.S. 830 (1980); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726 , 565 P.2d 1162 (1977).

11
Hecker v. Township of Dovergreen
scotus · 1980 · cited in 1 Washington opinions naming this issue, 1987–1987
2 sentences

1987See, e.g., Department of Natural Resources v. Thurston Cy., 92 Wn.2d 656 , 601 P.2d 494 (1979), cert. denied, 449 U.S. 830 (1980); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726 , 565 P.2d 1162 (1977).

1987See, e.g., Department of Natural Resources v. Thurston Cy., 92 Wn.2d 656 , 601 P.2d 494 (1979), cert. denied, 449 U.S. 830 (1980); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726 , 565 P.2d 1162 (1977).

11
MacDonald, Sommer & Frates v. Yolo Countygreen
scotus · 1986 · cited in 1 Washington opinions naming this issue, 1987–1987
2 sentences

1987We can uphold the trial court's summary judgment in Orion's favor only if we conclude that no genuine issues of material fact exist concerning the three components of a regulatory takings claim: (1) whether the regulatory regime as applied to Orion's property scheme was insulated from a takings challenge as part of the State's authority to enact health and safety regulations, see Keystone Bituminous Coal Ass'n v. DeBenedictis, ___ U.S. ___, 94 L.Ed.2d 472, 491-93 , 107 S.Ct. 1232 (1987); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726, 733 , 565 P.2d 1162 (1977); (2) whether

1987We can uphold the trial court's summary judgment in Orion's favor only if we conclude that no genuine issues of material fact exist concerning the three components of a regulatory takings claim: (1) whether the regulatory regime as applied to Orion's property scheme was insulated from a takings challenge as part of the State's authority to enact health and safety regulations, see Keystone Bituminous Coal Ass'n v. DeBenedictis, ___ U.S. ___, 94 L.Ed.2d 472, 491-93 , 107 S.Ct. 1232 (1987); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726, 733 , 565 P.2d 1162 (1977); (2) whether

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Dolan v. City of Tigard green
scotus · 1994
2 sentences

2002Although Benchmark initially proposed to dedicate an additional five feet of right-of-way in order to make the half-width improvements, the city council expressly determined that Benchmark was not required to dedicate any land beyond the preexisting right-of-way to make such improvements. [3] The court analyzed the regulatory takings claim under the "essential nexus" standard announced in Nollan v. Cal. Coastal Comm'n, 483 U.S. 825 , 107 S.Ct. 3141 , 97 L.Ed.2d 677 (1987) and the "rough proportionality" standard set forth in Dolan v. City of Tigard, 512 U.S. 374 , 114 S.Ct. 2309 , 129 L.Ed.2d

2002Although Benchmark initially proposed to dedicate an additional five feet of right-of-way in order to make the half-width improvements, the city council expressly determined that Benchmark was not required to dedicate any land beyond the preexisting right-of-way to make such improvements. [3] The court analyzed the regulatory takings claim under the "essential nexus" standard announced in Nollan v. Cal. Coastal Comm'n, 483 U.S. 825 , 107 S.Ct. 3141 , 97 L.Ed.2d 677 (1987) and the "rough proportionality" standard set forth in Dolan v. City of Tigard, 512 U.S. 374 , 114 S.Ct. 2309 , 129 L.Ed.2d

22002–2002
Nollan v. California Coastal Commission green
scotus · 1987
2 sentences

2002The court analyzed the regulatory takings claim under the “essential nexus” standard announced in Nollan v. California Coastal Commission, 483 U.S. 825 , 107 S. Ct. 3141 , 97 L.

2002The court analyzed the regulatory takings claim under the “essential nexus” standard announced in Nollan v. California Coastal Commission, 483 U.S. 825 , 107 S. Ct. 3141 , 97 L.

22002–2002
cluster 760864 green
ca9 · 1999
2 sentences

2000Justice Joseph Story wrote: "All the property and vested rights of individuals are subject to such regulations of police as the legislature may establish with a view to protect the community and its several members against such use or employment thereof as would be injurious to society or unjust toward other individuals. " 2 JOSEPH STORY, COMMENTARIES ON THE CONSTITUTION OF THE UNITED STATES § 1954, at 700-01 (5th ed. 1891) (emphasis added) (quoting Commonwealth v. Alger with approval). [15] "Under the `character-of-the-regulation' prong of the regulatory takings analysis, `[a] "taking" may mo

2000“Under the ‘character-of-the-regulation’ prong of the regulatory takings analysis, ‘[a] “taking” may more readily be found when the interference with property can he characterized as a physical invasion by government than when interference arises from some public program adjusting the benefits and burdens of economic life to promote the social good.’ ” Thomas v. Anchorage Equal Rights Comm’n, 165 F.3d 692 , 709 (quoting Penn Cent., 438 U.S. at 124), withdrawn, 192 F.3d 1208 (9th Cir. 1999).

22000–2000
Kaiser Aetna v. United States green
scotus · 1979
2 sentences

2019United States, 444 U.S. 164, 175 , 100 S. Ct. 383 , 62 L.

2019United States, 444 U.S. 164, 175 , 100 S. Ct. 383 , 62 L.

12019–2019
Kinderace Llc v. City Of Sammamish neutral
washctapp · 2016
2 sentences

2018“In a regulatory takings claim, one threshold issue is whether a city’s decision denies a landowner a fundamental attribute of property ownership, such as the right to possess, exclude others, dispose of, or make some economically viable use of the property.” Kinderace LLC v. City of Sammamish, 194 Wn.

2018App. 835, 843 , 379 P.3d 135 (2016).

12018–2018
Kahuna Land Co. v. Spokane County green
washctapp · 1999
1 sentence

2016Kahuna Land Co. v. Spokane County, 94 Wn.

12016–2016
cluster 766327 green
ca9 · 1999
1 sentence

2000“Under the ‘character-of-the-regulation’ prong of the regulatory takings analysis, ‘[a] “taking” may more readily be found when the interference with property can he characterized as a physical invasion by government than when interference arises from some public program adjusting the benefits and burdens of economic life to promote the social good.’ ” Thomas v. Anchorage Equal Rights Comm’n, 165 F.3d 692 , 709 (quoting Penn Cent., 438 U.S. at 124), withdrawn, 192 F.3d 1208 (9th Cir. 1999).

12000–2000
Lochner v. New York red
scotus · 1905
2 sentences

1998Regarding the propriety of substantive due process as a overall concept, see Eastern Enters., 118 S. Ct. at 2153 (section IV-D of plurality opinion); Lochner v. New York, 198 U.S. 45 , 25 S. Ct. 539 , 49 L.

1998Regarding the propriety of substantive due process as a overall concept, see Eastern Enters., 118 S. Ct. at 2153 (section IV-D of plurality opinion); Lochner v. New York, 198 U.S. 45 , 25 S. Ct. 539 , 49 L.

11998–1998
Orion Corporation v. State green
wash · 1987
2 sentences

1998See generally id. at 667 (Talmadge, J., concurring); Orion Corp. v. State, 109 Wn.2d 621, 646 , 747 P.2d 1062 (noting, without approval, that “commentators have also pointed out that the regulatory takings doctrine and the longstanding substantive due process test seem analytically identical”), cert. denied, 486 U.S. 1022 (1988).

1998See generally id. at 667 (Talmadge, J., concurring); Orion Corp. v. State, 109 Wn.2d 621, 646 , 747 P.2d 1062 (noting, without approval, that “commentators have also pointed out that the regulatory takings doctrine and the longstanding substantive due process test seem analytically identical”), cert. denied, 486 U.S. 1022 (1988).

11998–1998
Massachusetts v. Oakes green
scotus · 1988
1 sentence

1998See generally id. at 667 (Talmadge, J., concurring); Orion Corp. v. State, 109 Wn.2d 621, 646 , 747 P.2d 1062 (noting, without approval, that “commentators have also pointed out that the regulatory takings doctrine and the longstanding substantive due process test seem analytically identical”), cert. denied, 486 U.S. 1022 (1988).

11998–1998
Margaret Kinzli Evelyn Goossen Philip Kinzli Ernest Kinzli, Plaintiffs v. City of Santa Cruz green
ca9 · 1987
1 sentence

1989The court in Herrington relied on Kinzli v. Santa Cruz, 818 F.2d 1449 (9th Cir. 1987), a case involving a regulatory takings challenge.

11989–1989
Agins v. City of Tiburon red
scotus · 1980
2 sentences

1989Agins v. Tiburon, 447 U.S. 255, 260 , 65 L.

1989Agins v. Tiburon, 447 U.S. 255, 260 , 65 L.

11989–1989
Pennsylvania Coal Co. v. Mahon green
scotus · 1922
2 sentences

1987Pennsylvania Coal Co. v. Mahon, 260 U.S. 393, 415 , 67 L.Ed. 322 , 43 S.Ct. 158 (1922); Hamilton Bank , at 186.

1987Pennsylvania Coal Co. v. Mahon, 260 U.S. 393, 415 , 67 L.Ed. 322 , 43 S.Ct. 158 (1922); Hamilton Bank , at 186.

11987–1987
Maple Leaf Investors, Inc. v. Department of Ecology green
wash · 1977
2 sentences

1987We can uphold the trial court's summary judgment in Orion's favor only if we conclude that no genuine issues of material fact exist concerning the three components of a regulatory takings claim: (1) whether the regulatory regime as applied to Orion's property scheme was insulated from a takings challenge as part of the State's authority to enact health and safety regulations, see Keystone Bituminous Coal Ass'n v. DeBenedictis, ___ U.S. ___, 94 L.Ed.2d 472, 491-93 , 107 S.Ct. 1232 (1987); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726, 733 , 565 P.2d 1162 (1977); (2) whether

1987We can uphold the trial court's summary judgment in Orion's favor only if we conclude that no genuine issues of material fact exist concerning the three components of a regulatory takings claim: (1) whether the regulatory regime as applied to Orion's property scheme was insulated from a takings challenge as part of the State's authority to enact health and safety regulations, see Keystone Bituminous Coal Ass'n v. DeBenedictis, ___ U.S. ___, 94 L.Ed.2d 472, 491-93 , 107 S.Ct. 1232 (1987); Maple Leaf Investors, Inc. v. Department of Ecology, 88 Wn.2d 726, 733 , 565 P.2d 1162 (1977); (2) whether

11987–1987
Wilson v. Steinbach green
wash · 1982
2 sentences

1987Wilson v. Steinbach, 98 Wn.2d 434 , 656 P.2d 1030 (1982). 1.

1987Wilson v. Steinbach, 98 Wn.2d 434 , 656 P.2d 1030 (1982). 1.

11987–1987

Statutes the citing opinions construe

WA § Wash. Rev. Code § 36.70C.130 (3) WA § Wash. Rev. Code § 49.60.222 (3) WA § Wash. Rev. Code § 82.02.020 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 75 (1991–2025) CT 22 (1991–2017) CA 16 (1998–2023) WA 11 (1987–2019) OH 11 (2002–2026) FL 6 (1998–2018) WI 6 (1993–2017) IL 6 (2001–2020) NC 5 (2015–2022) MA 5 (1992–2004) OR 5 (1992–2010) MI 4 (2010–2025) TN 4 (2005–2014) MN 4 (2007–2018) NY 4 (1990–2017) CO 4 (1994–2025) VT 3 (1995–2026) MD 3 (1996–2019) SC 3 (1990–2023) IA 3 (1988–2005) NM 3 (2020–2021) IN 2 (2008–2019) PA 2 (1995–2020) NH 2 (2009–2024) MT 2 (2008–2008) NJ 2 (2019–2025) RI 2 (2000–2019) ND 2 (2005–2025) UT 2 (2004–2013) ME 2 (1997–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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