Pakdel v. City and County of San Francisco, 594 U.S. 474

Background

Petitioners are partial owners of a multiunit San Francisco building organized as a tenancy-in-common who sought to convert to condominium ownership.
San Francisco’s conversion program requires non‑occupant owners who rent units to offer tenants a lifetime lease; petitioners agreed and received conversion approval.
After approval, petitioners asked the city to excuse them from the lifetime-lease requirement or to compensate them; the city refused and warned of enforcement.
Petitioners sued under 42 U.S.C. §1983 alleging the lifetime-lease requirement was a regulatory taking; the District Court dismissed as unripe under Williamson County (because petitioners had not pursued state inverse-condemnation relief).
The Ninth Circuit affirmed but added that petitioners’ claim was not “final” because they had not followed the agency’s prescribed administrative procedures (they had made a belated exemption request).
The Supreme Court granted certiorari, held that finality does not require exhausting state administrative remedies once the government has adopted a definitive position, vacated the Ninth Circuit, and remanded.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a regulatory‑takings §1983 claim is ripe without pursuing state administrative or state‑court compensation remedies	Pakdel: Claim is ripe because the city took a definitive position—refusal to grant exemption—causing an injury	City: Claim not ripe because petitioners failed to follow prescribed administrative procedures and thus no true "final" decision	The Court: Ripeness requires only a definitive, conclusive government position as to how regulation applies; exhaustion of state remedies is not required for §1983 takings claims
Whether failure to comply with agency procedural rules (timeliness of exemption request) defeats finality	Pakdel: Late request does not negate that the agency has taken a final, injurious position	City/Ninth Cir.: Late/request‑after‑deadline shows agency still had discretion; decision not "final" without proper procedural exhaustion	The Court: Procedural missteps may affect merits or damages but do not defeat ripeness once the government has adopted a final position
Whether Williamson County’s state‑court compensation requirement survives Knick and applies here	Pakdel: Knick overruled Williamson County’s state‑court exhaustion rule; federal forum under §1983 remains available	Ninth Cir.: Relied on Williamson County’s finality prong; sought to preserve a de facto exhaustion requirement by requiring compliance with administrative procedures	The Court: Knick rejected the state‑court exhaustion rule; courts cannot require exhaustion of state remedies as a prerequisite to §1983 takings suits when finality is otherwise satisfied

Key Cases Cited

Suitum v. Tahoe Reg. Planning Agency, 520 U.S. 725 (ripeness finality requires clarity how regulation applies to land)
Horne v. Dep’t of Agriculture, 569 U.S. 513 (ripeness requires actual injury from government action)
Knick v. Twp. of Scott, 588 U.S. _ (§1983 takings claims need not await state inverse‑condemnation proceedings)
Williamson Cnty. Reg’l Planning Comm’n v. Hamilton Bank, 473 U.S. 172 (distinguished — finality vs. exhaustion principles)
MacDonald, Sommer & Frates v. Yolo Cnty., 477 U.S. 340 (ripeness requires knowing how far regulation goes)
Woodford v. Ngo, 548 U.S. 81 (administrative exhaustion doctrine requires proper compliance with agency procedures)
Palazzolo v. Rhode Island, 533 U.S. 606 (administrative timing and procedural posture may affect merits but not necessarily ripeness)
Cedar Point Nursery v. Hassid, 141 S. Ct. 2063 (recent takings law guidance referenced for related claims)