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Keywords

lawsuitdamagestrialdue processjury trialjury instructions
trialrespondentjury trial

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City of Monterey v. Del Monte Dunes at Monterey, Ltd., 526 U.S. 687, 119 S.Ct. 1624, 143 L.Ed.2d 882, 48 ERC 1513, 67 USLW 3681, 67 USLW 4345, 29 Envtl. L. Rep. 21,133, 99 Cal. Daily Op. Serv. 3846, 1999 Daily Journal D.A.R. 4908, 1999 CJ C.A.R. 3019, 12 Fla. L. Weekly Fed. S 247

Facts

Del Monte Dunes and its predecessor sought to develop a 37.6-acre parcel of land in Monterey, California, but faced repeated rejections from the city, which imposed increasingly rigorous demands on their proposals. After five years and multiple site plans, the city denied the final development proposal, claiming it did not meet various conditions. Del Monte Dunes alleged that the city's actions constituted a regulatory taking without just compensation, leading to the lawsuit under § 1983.

After petitioner city imposed more rigorous demands each of the five times it rejected applications to develop a parcel of land owned by respondent Del Monte Dunes and its predecessor in interest, Del Monte Dunes brought this suit under 42 U.S.C. § 1983.

Issue

Did the city of Monterey's repeated rejections of Del Monte Dunes' development proposals constitute a violation of the owner's equal protection and due process rights, and did it amount to a regulatory taking?

The controlling question is whether, given the city's apparent concession that the instructions were a correct statement of the law, the matter was properly submitted to the jury.

Rule

The court held that an action under § 1983 is an 'action at law' within the meaning of the Seventh Amendment, which guarantees the right to a jury trial. The jury must determine whether the city's actions deprived the property owner of all economically viable use of the land and whether the city's decisions were reasonably related to legitimate public interests.

Because § 1983 does not itself confer the jury right when it authorizes 'an action at law' to redress deprivation of a federal right under color of state law, the constitutional question must be reached.

Analysis

The court applied the rule by determining that the jury was properly tasked with deciding whether Del Monte Dunes had been denied all economically viable use of its property and whether the city's rejection of the development proposal substantially advanced a legitimate public purpose. The jury instructions, which were proposed by the city, guided the jury to consider the relationship between the city's actions and its stated objectives.

The jury found for Del Monte Dunes. In affirming, the Ninth Circuit ruled, inter alia, that the District Court did not err in allowing Del Monte Dunes' takings claim to be tried to a jury, because Del Monte Dunes had a right to a jury trial under § 1983.

Conclusion

The Supreme Court affirmed the Ninth Circuit's ruling, concluding that the jury's findings were supported by the evidence and that Del Monte Dunes was entitled to a jury trial under § 1983.

Held: The judgment is affirmed.

Who won?

Del Monte Dunes prevailed in the case, as the jury found in its favor on the takings claim and awarded damages, affirming that the city's actions constituted a regulatory taking.

Del Monte Dunes decided the city would not permit development of the property under any circumstances.

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