inverse condemnation claim (Arizona) · Go Syfert
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inverse condemnation claim in Arizona

7 Arizona opinions name it 1 courts 2002–2020 0 in the last five years

The cases below were cited by Arizona 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 (7)

CaseFollowedCited
Acuna v. Kroackgreen
arizctapp · 2006 · cited in 2 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See Acuna v. Kroack, 212 Ariz. 104, 110, ¶ 23 , 128 P.3d 221, 227 (App.2006) (reviewing de novo denial of motion for judgment as a matter of law). ¶35 Under the Arizona Constitution, property shall not be “taken or damaged” without just compensation.

2007See Acuna v. Kroack, 212 Ariz. 104, 110, ¶ 23 , 128 P.3d 221, 227 (App.2006) (reviewing de novo denial of motion for judgment as a matter of law). ¶35 Under the Arizona Constitution, property shall not be “taken or damaged” without just compensation.

22
Flood Control Dist. v. Gainesgreen
arizctapp · 2002 · cited in 2 Arizona opinions naming this issue, 2013–2014
2 sentences

2014We disagree. ¶11 In Flood Control District. of Maricopa County. v. Gaines, this court upheld the constitutionality of A.R.S. § 12-821 as applied to state constitutional claims “because it regulates rather than abrogates the time within which an action must be filed against a public entity.” 202 Ariz. 248 , 254, ¶ 18, 43 P.3d 196 , 202 (App. 2002) (applying A.R.S. § 12-821 to an inverse condemnation claim).

2014We disagree. ¶11 In Flood Control District. of Maricopa County. v. Gaines, this court upheld the constitutionality of A.R.S. § 12-821 as applied to state constitutional claims “because it regulates rather than abrogates the time within which an action must be filed against a public entity.” 202 Ariz. 248 , 254, ¶ 18, 43 P.3d 196 , 202 (App. 2002) (applying A.R.S. § 12-821 to an inverse condemnation claim).

12
City of Tucson v. Clear Channel Outdoor, Inc.green
ariz · 2005 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013City of Tucson v. Clear Channel Outdoor, Inc., 209 Ariz. 544, 547, ¶ 8 , 105 P.3d 1163, 1166 (2005). ¶ 7 Cook initially argues that § 12-821 does not apply to his claim against the Town, a claim he characterizes on appeal as an inverse condemnation claim.

2013City of Tucson v. Clear Channel Outdoor, Inc., 209 Ariz. 544, 547, ¶ 8 , 105 P.3d 1163, 1166 (2005). ¶ 7 Cook initially argues that § 12-821 does not apply to his claim against the Town, a claim he characterizes on appeal as an inverse condemnation claim.

11
State v. Mabery Ranch, Co., L.L.C.green
arizctapp · 2007 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013See State v. Mabery Ranch Co., 216 Ariz. 233, 249, ¶ 74 , 165 P.3d 211 , 227 (App.2007) (noting “there is a significant distinction between a cause of action for damages ... and a cause of action to quiet title, which seeks a judicial determination of title, rather than damages”).

2013An inverse condemnation claim requires the claimant to allege “the government either assumes actual possession of the property or places a legal constraint upon the property that substantially diminishes or destroys the owner’s right to, and use [ ] of, the property.” Mabery Ranch, 216 Ariz. at 242, ¶ 35 , 165 P.3d at 220 (citation omitted).

11
Canyon Del Rio Investors, L.L.C. v. City of Flagstaffgreen
arizctapp · 2011 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013See Flood Control Dist. of Maricopa Cnty. v. Gaines, 202 Ariz. 248, 251, ¶ 6 , 43 P.3d 196, 199 (App.2002); Canyon Del Rio Investors, L.L.C. v. City of Flagstaff, 227 Ariz. 336, 342, ¶ 24 , 258 P.3d 154, 160 (App.2011).

2013See Flood Control Dist. of Maricopa Cnty. v. Gaines, 202 Ariz. 248, 251, ¶ 6 , 43 P.3d 196, 199 (App.2002); Canyon Del Rio Investors, L.L.C. v. City of Flagstaff, 227 Ariz. 336, 342, ¶ 24 , 258 P.3d 154, 160 (App.2011).

11
State v. MABERY RANCH, CO., LLCgreen
arizctapp · 2007 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013See State v. Mabery Ranch Co., 216 Ariz. 233, 249, ¶ 74 , 165 P.3d 211 , 227 (App.2007) (noting “there is a significant distinction between a cause of action for damages ... and a cause of action to quiet title, which seeks a judicial determination of title, rather than damages”).

2013An inverse condemnation claim requires the claimant to allege “the government either assumes actual possession of the property or places a legal constraint upon the property that substantially diminishes or destroys the owner’s right to, and use [ ] of, the property.” Mabery Ranch, 216 Ariz. at 242, ¶ 35 , 165 P.3d at 220 (citation omitted).

11
Blanchard v. Show Low Planning & Zoning Commissiongreen
arizctapp · 1999 · cited in 1 Arizona opinions naming this issue, 2006–2006
2 sentences

2006After oral argument the court ordered the parties to file supplemental briefs regarding appellants’ inverse condemnation claims. ¶ 6 In their supplemental briefing, appellants argued that the enactment of the Ordinance constituted an “as-applied” taking pursuant to the three-pronged test derived from Penn Central Transportation Company v. City of New York, 438 U.S. 104 , 98 S.Ct. 2646 , 57 L.Ed.2d 631 (1978). 3 *162 ¶ 7 Treating the City’s motion as one for summary judgment because both parties presented materials beyond the pleadings, see Blanchard v. Show Low Planning & Zoning Comm’n, 196 Ar

2006After oral argument the court ordered the parties to file supplemental briefs regarding appellants’ inverse condemnation claims. ¶ 6 In their supplemental briefing, appellants argued that the enactment of the Ordinance constituted an “as-applied” taking pursuant to the three-pronged test derived from Penn Central Transportation Company v. City of New York, 438 U.S. 104 , 98 S.Ct. 2646 , 57 L.Ed.2d 631 (1978). 3 *162 ¶ 7 Treating the City’s motion as one for summary judgment because both parties presented materials beyond the pleadings, see Blanchard v. Show Low Planning & Zoning Comm’n, 196 Ar

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
State v. Dawson neutral
ariz · 1993
1 sentence

2020Miller v. Dawson, 175 Ariz. 610 (1993) is contrary to the ruling that the inverse condemnation claim belonged to the former owners because Dawson allowed subsequent property owners to press an inverse condemnation claim.

12020–2020
Penn Central Transportation Co. v. New York City green
scotus · 1978
2 sentences

2006After oral argument the court ordered the parties to file supplemental briefs regarding appellants’ inverse condemnation claims. ¶ 6 In their supplemental briefing, appellants argued that the enactment of the Ordinance constituted an “as-applied” taking pursuant to the three-pronged test derived from Penn Central Transportation Company v. City of New York, 438 U.S. 104 , 98 S.Ct. 2646 , 57 L.Ed.2d 631 (1978). 3 *162 ¶ 7 Treating the City’s motion as one for summary judgment because both parties presented materials beyond the pleadings, see Blanchard v. Show Low Planning & Zoning Comm’n, 196 Ar

2006After oral argument the court ordered the parties to file supplemental briefs regarding appellants’ inverse condemnation claims. ¶ 6 In their supplemental briefing, appellants argued that the enactment of the Ordinance constituted an “as-applied” taking pursuant to the three-pronged test derived from Penn Central Transportation Company v. City of New York, 438 U.S. 104 , 98 S.Ct. 2646 , 57 L.Ed.2d 631 (1978). 3 *162 ¶ 7 Treating the City’s motion as one for summary judgment because both parties presented materials beyond the pleadings, see Blanchard v. Show Low Planning & Zoning Comm’n, 196 Ar

12006–2006
Klopping v. City of Whittier green
cal · 1972
2 sentences

2002Judge Pillinger concluded that there was no taking of DUWA’s property under Arizona law because Tempe neither physically invaded DUWA’s property nor substantially interfered with its ingress or egress. 3 The court was not persuaded by a California case relied upon by DUWA, Klopping v. City of Whittier, 8 Cal.3d 39 , 104 Cal.Rptr. 1 , 500 P.2d 1345 (1972), that allowed an inverse condemnation claim arising out of pre-condemnation announcements by a public entity that reduced property values.

2002Judge Pillinger concluded that there was no taking of DUWA’s property under Arizona law because Tempe neither physically invaded DUWA’s property nor substantially interfered with its ingress or egress. 3 The court was not persuaded by a California case relied upon by DUWA, Klopping v. City of Whittier, 8 Cal.3d 39 , 104 Cal.Rptr. 1 , 500 P.2d 1345 (1972), that allowed an inverse condemnation claim arising out of pre-condemnation announcements by a public entity that reduced property values.

12002–2002
Uvodich v. Arizona Board of Regents green
arizctapp · 1969
2 sentences

2002DUWA contends that the broader language of the Arizona Constitution provides for recovery in cases, such as this one, where the governing authority’s acts have “damaged” the value of the property even though the government has not initiated an eminent domain proceeding or otherwise asserted control over the property. ¶ 18 This court previously rejected a similar inverse condemnation claim for “depreciation in value.” Uvodich v. Arizona Bd. of Regents, 9 Ariz.App. 400 , 453 P.2d 229 (1969).

2002DUWA contends that the broader language of the Arizona Constitution provides for recovery in cases, such as this one, where the governing authority’s acts have “damaged” the value of the property even though the government has not initiated an eminent domain proceeding or otherwise asserted control over the property. ¶ 18 This court previously rejected a similar inverse condemnation claim for “depreciation in value.” Uvodich v. Arizona Bd. of Regents, 9 Ariz.App. 400 , 453 P.2d 229 (1969).

12002–2002

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-821.01 (7) AZ § Ariz. Rev. Stat. § 12-821 (6) AZ § Ariz. Rev. Stat. § 12-2101 (4) AZ § Ariz. Rev. Stat. § 12-1101 (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 229 (1999–2026) CA 74 (1962–2026) WA 35 (1976–2024) MI 26 (1996–2026) CO 25 (1988–2019) GA 24 (2004–2026) CT 23 (1990–2025) FL 22 (1982–2019) NC 20 (2006–2026) OR 18 (1987–2024) SC 15 (2005–2025) WI 14 (1993–2026) NJ 14 (1985–2020) AL 12 (1981–2026) VA 11 (1984–2026) NM 11 (1995–2021) NV 9 (1997–2016) IA 9 (1988–2018) IL 9 (1986–2025) MN 9 (1994–2025) ND 9 (1981–2019) ID 9 (1993–2025) MT 8 (1988–2024) MD 8 (1986–2020) AZ 7 (2002–2020) TN 7 (1999–2019) AK 6 (1990–2020) UT 6 (1990–2015) NY 6 (1965–2019) KS 6 (1997–2017) MO 6 (1990–2008) LA 5 (1985–2011) OK 5 (2011–2022) MS 5 (2018–2026) NH 5 (2010–2012) ME 4 (2000–2023) HI 3 (2009–2020) NE 3 (2015–2017) RI 3 (1998–2009) SD 2 (2017–2018) IN 2 (2009–2023) WY 2 (2005–2007)

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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