Judge Finds Foul Odor of Sorts in Tampa Bay Land-Use Case
“What happened to Hillcrest here was pretty doggone s[tink]y,” Judge Kevin Newsom wrote. But he agreed with Judge Gerald Tjoflat that foul smelling does not equal unconstitutional.
February 15, 2019 at 02:43 PM
5 minute read
The original version of this story was published on Daily Report
“Not everything that s[tink]s violates the Constitution,” Judge Kevin Newsom of the U.S. Court of Appeals for the Eleventh Circuit said in a special concurrence on a Tampa Bar area due process opinion that's generating #AppellateTwitter buzz. “If ever a case proved the truth of that little nugget, this is it.”
Newsom said he was borrowing a 20-year-old quote from “an insightful (and hilarious) lawyer friend” and using a euphemism to cover his friend's more colorful vocabulary.
“Because this is a family show, I'll clean it up a bit,” the judge said.
Newsom used his concurrence to highlight issues while still agreeing with Judge Gerald Tjoflat, who was also joined by Judge Stanley Marcus.
Georgia Court of Appeals Judge Stephen Dillard flagged the ruling for his 15,000 Twitter followers. “I think Judge Kevin Newsom's latest opinion, a special concurrence, will be of some interest to #AppellateTwitter and many of my law professor friends,” Dillard tweeted after the opinion posted online.
Over the next day or so, the tweet generated kind comments — true to Dillard's Twitter style — though one complained of too many dashes. Mostly they deemed Newsom's writing great, impressive and enjoyable, while finding amusement in their own late-night reading preferences.
But first, Tjoflat set the stage.
“The question before us is whether a litigant in this Circuit has a substantive-due-process claim under the Due Process Clause of the Fourteenth Amendment when the alleged conduct is the unlawful application of a land-use ordinance,” Tjoflat wrote. “The answer to that question is a resounding 'no'—an answer that this Court delivered in McKinney v. Pate, 20 F.3d 1550 (11th Cir. 1994) (en banc), 24 years ago and has reaffirmed ever since.”
Tjoflat would know, after serving on the court since 1975 — and writing the McKinney opinion.
“We held in McKinney that executive action never gives rise to a substantive-due-process claim unless it infringes on a fundamental right,” Tjoflat said. “A land-use decision is classic executive, rather than legislative, action — action that, at least here, does not implicate a fundamental right under the Constitution.”
The appeal from the Middle District of Florida came in a dispute between Pasco County and Hillcrest Property.
The county ordinance in question aimed “to protect transportation corridors from encroachment” by development, Tjoflat said. When a developer seeks a permit, the county requires a right-of-way dedication as a condition.
Hillcrest Property owned 16.5 vacant acres and applied in 2006 to develop an 83,000-square-foot retail shopping center. In February 2007, the county the dedication of 50 feet for the future expansion of State Road 52 to four lanes. A few months later, the county said it would need an additional 90 feet for a total of 140 feet. The county was to compensate Hillcrest for the additional land but then years later said it was unable to pay, Tjoflat said.
Hillcrest sued the county, alleging violations of the takings clause of the Fifth Amendment, as incorporated by the Fourteenth Amendment. The company also made due process claims under the Fourteenth Amendment.
The trial court granted summary judgment on some of Hillcrest's claims but not others and enjoined the county from taking the land. The county appealed. “We accordingly vacated the District Court's order but expressed 'no view as to the merits of Hillcrest's pending as-applied substantive due process claim,' ” Tjoflat said. “The litigation continued.”
Now Tjoflat said, “We must decide the one claim that lingers and put this case to rest.” That would be the due process claim. Tjoflat explained why he found it lacking.
“We cannot be clearer on this point: regardless of how arbitrarily or irrationally the County has acted with respect to Hillcrest, Hillcrest has no substantive-due-process claim,” Tjoflat concluded. He reversed the district court's grant of summary judgment to Hillcrest.
“What happened to Hillcrest here was pretty doggone s[tink]y,” Newsom wrote in his special concurrence, again quoting his old friend mentioned earlier. The county was demanding 4.5 acres, more than a quarter of Hillcrest's land.
“Over the course of the next few years, the parties continued to haggle, the county continued to deny Hillcrest's construction permits, and Hillcrest — presumably feeling like it was trapped in some Ayn-Rand-ian nightmare — eventually sued,” Newsom said.
Newsom analyzed constitutional law and prior relevant decisions, saying he went with the majority by a different path.
“To be clear, I think the majority has it exactly right under our existing precedent,” Newsom said. “I'm just not convinced that our precedent has it exactly right.”
Hillcrest was represented by David Smolker and Ethan Loeb of Smolker Bartlett Loeb Hinds & Thompson in Tampa.
The county was represented by Donald Hemke and H. Raymond Allen II of Carlton Fields in Tampa.
The lawyers did not respond by deadlines to requests for comment.
The case is Hillcrest Property v. Pasco County, No. 17-14789.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllFowler White Burnett Opens Jacksonville Office Focused on Transportation Practice
3 minute readHow Much Coverage Do You Really Have? Valuation and Loss Settlement Provisions in Commercial Property Policies
10 minute readThe Importance of 'Speaking Up' Regarding Lease Renewal Deadlines for Commercial Tenants and Landlords
6 minute readMeet the Attorneys—and Little Known Law—Behind $20M Miami Dispute
Trending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250