THOMAS GEARING V. CITY OF HALF MOON BAY, 54 F.4th 1144

Thomas and Daniel Gearing own six undeveloped parcels in Half Moon Bay zoned for public recreation and subject to LUP §9.3.5, which conditions development on an approved master/specific plan.
The Gearings submitted a development proposal under California SB 330; the City denied it, saying no master plan existed and SB 330 did not compel approval.
After the Gearings sued in federal court under 42 U.S.C. § 1983 claiming a regulatory taking, the City filed a state-court eminent domain action to acquire the parcels.
The City moved in federal court for Pullman abstention (stay) pending resolution of the state eminent domain action; the district court granted the motion.
The Gearings appealed, arguing Knick and Pakdel foreclose abstention when it creates an "effective exhaustion" requirement and alternatively that Pullman’s requirements were not met.
The Ninth Circuit affirmed, holding Knick and Pakdel do not bar Pullman abstention here and that the Pullman factors are satisfied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Knick and Pakdel preclude Pullman abstention when abstention would require litigating takings-related issues in state court (i.e., create an "effective exhaustion" requirement).	The Gearings: Knick and Pakdel rejected state-forum exhaustion for takings claims, so Pullman abstention that effectively forces state litigation is barred.	The City: Knick/Pakdel address ripeness/exhaustion, not abstention; Pullman permits staying accrued federal claims for state-law resolution and does not impose an exhaustion requirement here.	Affirmed for City: Knick and Pakdel do not preclude Pullman abstention; abstention is compatible because the state eminent domain action can proceed without resolving the federal takings claim and an England reservation preserves federal forum.
Whether the three Pullman factors are satisfied (sensitive social policy, state-law ruling may narrow/moot the federal question, and state-law issue is unclear).	The Gearings: The factors are not met and abstention is inappropriate.	The City: Land-use is a sensitive area; state court interpretation of LUP §9.3.5 and SB 330 will likely narrow the federal takings claim; SB 330 interaction with local plans is unsettled.	Affirmed for City: All three Pullman factors are met — land-use is sensitive; state adjudication could narrow/moot; state-law questions are uncertain.

Railroad Comm’n v. Pullman Co., 312 U.S. 496 (abstention doctrine allowing federal courts to defer to state courts on controlling state-law issues).
Knick v. Township of Scott, 139 S. Ct. 2162 (Supreme Court 2019) (rejected Williamson County’s requirement to seek just compensation in state court before bringing a federal §1983 takings claim).
Pakdel v. City and County of San Francisco, 141 S. Ct. 2226 (Supreme Court 2021) (clarified Williamson County final-decision ripeness requirement is modest).
Williamson County Reg’l Planning Comm’n v. Hamilton Bank, 473 U.S. 172 (prior ripeness/exhaustion framework for takings claims).
Lingle v. Chevron U.S.A. Inc., 544 U.S. 528 (regulatory takings analysis and damages/remedies distinction).
San Remo Hotel v. City & County of San Francisco, 545 U.S. 323 (Supreme Court 2005) (discussing Pullman abstention after finding a ripe federal takings question).
Sinclair Oil Corp. v. County of Santa Barbara, 96 F.3d 401 (9th Cir. 1996) (describing Pullman factors in land-use context).
England v. Louisiana State Bd. of Medical Examiners, 375 U.S. 411 (allows litigants to reserve federal claims when litigating related issues in state court).