Wayside Church v. Van Buren County
847 F.3d 812
6th Cir.2017Background
- Plaintiffs (Wayside Church, Stahl, Hodgens) each forfeited Michigan real property for unpaid 2011 taxes; county foreclosure judgments (2014) vested fee simple title in Van Buren County, which sold the properties at auction and realized large surpluses over the statutory minimum bids.
- Plaintiffs sued the county and county treasurer in federal court, claiming the failure to return surplus sale proceeds constituted a Fifth Amendment taking without just compensation; they sought declaratory relief and § 1983 damages and proposed a class of similarly situated former owners.
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) (jurisdiction) and 12(b)(6); the district court found subject-matter jurisdiction but dismissed for failure to state a claim.
- Defendants cross‑appealed the jurisdictional ruling; the Sixth Circuit considered the 12(b)(1) (ripeness/Tax Injunction Act/comity) issues first.
- The Sixth Circuit majority held plaintiffs’ federal takings claims were not ripe for federal adjudication because Michigan state courts provided reasonable, certain, and adequate remedies (contrary to the district court’s reading of the GPTA), and that the Tax Injunction Act/comity doctrines precluded federal jurisdiction.
- Court disposition: vacated the district court judgment and remanded with instructions to dismiss for lack of subject-matter jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ripeness under Williamson County for Takings Clause claims | Plaintiffs: federal takings claim ripe because GPTA forces Court of Claims jurisdiction but that court cannot hear claims where a federal remedy exists, so no adequate state remedy exists | Defendants: state procedures (e.g., inverse condemnation in state courts or GPTA remedies) are adequate; plaintiffs must seek state compensation first | Held: Plaintiffs may pursue federal takings claims in Michigan state courts (circuit court or appropriate forum); state remedies are adequate so federal claim not ripe—dismiss for lack of jurisdiction |
| Statutory interpretation of GPTA § 211.78i and Court of Claims exclusivity | Plaintiffs: GPTA confines relief to Court of Claims and that court is barred when federal remedy exists, leaving no state forum | Defendants: GPTA does not bar constitutional challenges in state courts; § 211.78i limited to notice-based claims and does not preclude other suits | Held: Majority rejects district court’s restrictive reading; § 211.78i applies to notice claims only; plaintiffs not forced out of state forums |
| Tax Injunction Act and doctrine of comity (bar on federal review of state tax matters) | Plaintiffs: federal courts available because GPTA eliminated adequate state remedy | Defendants: § 1341 and comity bar federal equitable and some monetary challenges where state courts offer plain, adequate, complete remedies | Held: State courts provide plain, adequate, and complete remedies; Tax Injunction Act and comity bar federal adjudication here |
| Proper forum for monetary/§ 1983 claims against county/treasurer | Plaintiffs: federal forum necessary to vindicate constitutional takings right; state forum unavailable or inadequate | Defendants: concurrent state-court jurisdiction exists (circuit court or Court of Claims depending on party) | Held: Plaintiffs could have sought relief in Michigan state courts; federal court lacked jurisdiction |
Key Cases Cited
- Lingle v. Chevron U.S.A. Inc., 544 U.S. 528 (clarifies Takings Clause purpose and inquiry)
- Williamson County Reg'l Planning Comm'n v. Hamilton Bank, 473 U.S. 172 (ripeness test for takings: final decision and state compensation remedy)
- First English Evangelical Lutheran Church v. County of Los Angeles, 482 U.S. 304 (Takings Clause and requirement of compensation)
- Haywood v. Drown, 556 U.S. 729 (state jurisdictional rules cannot be used to undermine federal rights under Supremacy Clause)
- Fair Assessment in Real Estate Ass'n v. McNary, 454 U.S. 100 (comity principle; federal courts should refrain when state courts provide adequate remedies)