Amana Global Company v. King County, 2:21-cv-00637

Background:

King County purchased a warehouse property for a flood project; Plaintiffs (Tahraoui/Amana) held a lease through August 2021 but were targeted for relocation/condemnation.
County provided relocation notices, estimated benefits, and later offered $220,000 for the leasehold; Plaintiffs rejected the offer and filed a demand for $2.462 million.
County obtained a condemnation decree (decree of appropriation entered November 12, 2019) and thereafter Plaintiffs were found to be unlawful occupants; eviction occurred May 10, 2021.
King County paid over $160,000 directly to Plaintiffs and over $2.5 million to movers/storage to relocate Plaintiffs’ property; Plaintiffs pursued state and federal litigation challenging relocation benefits and procedures.
The state courts affirmed condemnation and eviction; Plaintiffs filed this federal § 1983 action alleging procedural due process, equal protection, and preemption by federal URA regulations.
The district court granted Defendants’ summary judgment, struck Plaintiffs’ amended motion as untimely, and dismissed the action based on claim/issue preclusion (and related legal failures).

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction / Rooker‑Feldman and preclusion	Tahraoui argued Rooker‑Feldman doesn’t bar suit because appeal of condemnation was pending when federal suit filed	County argued federal review is barred or precluded by state-court adjudication; preclusion applies	Court: Rooker‑Feldman limited by Exxon but claim and issue preclusion under Washington law bar relitigation; claims precluded
Status as "displaced person" entitled to URA benefits	Tahraoui: remained a lawful occupant/displaced person entitled to relocation benefits and 90‑day notice	County: lease terminated by condemnation; Plaintiffs became unlawful occupants excluded from "displaced person" status	Held: Plaintiffs became unlawful occupants after condemnation and thus not entitled to URA/Wash. relocation benefits or 90‑day notices
Federal preemption / "equitable preemption" of state statutes	Tahraoui: RCW and WAC, as applied, conflict with 49 C.F.R. relocation rules; seeks relocation payments	County: URA/regulations apply only to displaced persons; state statutes don’t conflict as applied	Held: Preemption claim fails because Plaintiffs are not displaced persons and thus have no URA entitlement
Procedural due process / equal protection / conspiracy claims	Tahraoui: denial of relocation benefits was arbitrary, discriminatory; sought declaratory and § 1983 relief	County: constitutional claims were or could have been litigated in state action; no policy violation shown; individual defendants entitled to qualified immunity	Held: Claims are precluded by the prior state litigation (claim/issue preclusion); merits also fail because no entitlement to benefits

Key Cases Cited

Rooker v. Fidelity Tr. Co., 263 U.S. 413 (U.S. 1923) (federal courts lack jurisdiction to review final state-court judgments)
Dist. of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (Rooker‑Feldman bars federal review of state‑court adjudications even when federal questions are raised)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (limits Rooker‑Feldman; state‑court losers may be subject to preclusion rules rather than jurisdictional bar)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (standard for summary judgment and genuine dispute inquiry)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (movant’s initial burden on summary judgment and how it may be met)
Sprague v. Spokane Valley Fire Dep’t, 189 Wn.2d 858 (Wash. 2018) (Washington collateral estoppel/issue preclusion factors)
Loveridge v. Fred Meyer, Inc., 125 Wn.2d 759 (Wash. 1995) (elements for claim preclusion under Washington law)