Clifton v. Village of Blanchester, 131 Ohio St. 3d 287

Clifton, a nonresident, owns land adjacent to J & M Precision Machining, Inc.’s 23 acres that lie near Blanchester, Ohio, but his property is mostly outside Blanchester’s municipal limits.
In 2002 Blanchester annexed and rezoned J & M’s entire property to general industrial, while Clifton’s 97–99 acres remained outside the village’s limits.
Clifton challenged the rezoning as unconstitutional and as a taking affecting his property, initially pursuing administrative appeals and later filing a takings claim in court.
The trial court and the court of appeals split on whether the rezoning could constitute a partial or regulatory taking against Clifton; the matter was remanded for a Penn Central analysis and for standing considerations.
The trial court ultimately held Clifton had no standing to pursue a takings claim and granted summary judgment to the village; the appellate court affirmed, concluding Clifton lacked standing.
The Ohio Supreme Court granted discretionary review to determine whether a neighboring landowner outside a municipality has standing to compel an adjacent village to initiate appropriation proceedings for a regulatory taking.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Clifton has standing to seek a partial regulatory-taking claim	Clifton argues a contiguous adjacent owner has standing to challenge zoning as a taking	Blanchester contends Clifton lacks the requisite standing since his property lies outside the village and not subject to the zoning	Clifton lacks standing
Whether redressability supports a standing claim where the affected property lies outside the municipality	Clifton contends the zoning change yields a redressable injury that can be remedied by mandamus to compel appropriation	Village argues it cannot appropriate Clifton’s outside-property, so redressability fails	No redressable claim against the village

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact and redressability)
Penn Cent. Transp. Co. v. New York City, 438 U.S. 104 (1978) (historical Penn Central takings framework guiding regulatory burdens)
State ex rel. Gilbert v. Cincinnati, 125 Ohio St.3d 385 (2010) (mandamus to compel appropriation for takings; home-rule limitations)
Lingle v. Chevron U.S.A., Inc., 544 U.S. 528 (2005) (economic impact and investment-backed expectations in takings analysis)
Murphy v. Detroit, 201 Mich. App. 54, 506 N.W.2d 5 (1993) (adjacent-property downturns do not automatically state a taking)
Gilmour Realty, Inc. v. Mayfield Heights, 119 Ohio St.3d 11 (2008) (zoning can cause takings considerations and require analysis)
Britt v. Columbus, 38 Ohio St.2d 1 (1974) (municipal eminent-domain power limited to within corporate limits)
Bruestle v. Rich, 159 Ohio St. 13 (1953) (home-rule and eminent-domain authorities of municipalities)