Guggenheim v. City of Goleta
2010 U.S. App. LEXIS 25981
| 9th Cir. | 2010Background
- Santa Barbara County enacted mobile-home rent control in 1979; amended in 1987.
- Guggenheims bought Ranch Mobile Estates in 1997, within territory later incorporated as City of Goleta in 2002.
- Goleta adopted the county ordinance on its first day of existence; later readopted it within the 120-day sunset period, effectively extending it citywide.
- Guggenheims filed a facial takings challenge alleging the ordinance transferred land-value from owners to tenants by suppressing rents and inflating home values.
- District court granted summary judgment; appellate history included a Lingle-driven re-evaluation; en banc court ultimately affirmed the grant of summary judgment.
- Court analyzes facial regulatory takings under Penn Central and related due process/equal protection claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Goleta's 2002 ordinance facially take property under Penn Central? | Guggenheims claim land value was transferred to tenants, constituting a taking. | Regulation has legitimate public purposes and does not meet Penn Central's taking standard. | No taking under Penn Central; balance of factors insufficient. |
| Are the due process and equal protection claims viable against the ordinance? | Ordinance irrational or discriminatory; violates substantive due process and equal protection. | Rational basis review suffices; ordinance rationally related to public housing goals. | Claims foreclosed or rationally related; no constitutional violation under governing precedents. |
| Was the Guggenheims' facial challenge ripe, and did standing exist to pursue the claim? | Had standing; facial challenge ripe despite prior ownership timing. | Ripeness and standing requirements applicable; facial challenge appropriately framed. | Standing affirmed; ripeness treated prudentially; court declined exhaustion requirement. |
Key Cases Cited
- Lingle v. Chevron U.S.A. Inc., 544 U.S. 528 (U.S. 2005) (overruled substantial-advances test; independent takings and due process analyses preserved)
- Penn Central Transportation Co. v. New York City, 438 U.S. 104 (U.S. 1978) (three-factor test: economic impact, character of government action, investment-backed expectations)
- Palazzolo v. Rhode Island, 533 U.S. 606 (U.S. 2001) (post-enactment ownership does not bar regulatory takings claim; investments expectations relevant)
- Yee v. City of Escondido, 503 U.S. 519 (U.S. 1992) (facial challenges can be ripe even if as-applied challenges are unripe)
- Levald, Inc. v. City of Palm Desert, 998 F.2d 680 (9th Cir. 1993) (facial challenge characterized as single harm; monetary impact may be measured at enactment)
- Cienega Gardens v. United States, 331 F.3d 1319 (Fed. Cir. 2003) (transfer of value and burdens can constitute a taking where burdens fall on a subset of landowners)
- Equity Lifestyle Props., Inc. v. County of San Luis Obispo, 548 F.3d 1184 (9th Cir. 2008) (rent-control takings and equal protection doctrines guiding facial challenges)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requirements framework (cited for standing theory))