Wayside Church v. Van Buren Cty., 15-2525

Background

In 2011 Plaintiffs Wayside Church, Myron Stahl, and Henderson Hodgens failed to pay property taxes in Van Buren County, Michigan; after foreclosure under the Michigan General Property Tax Act (GPTA) title vested in the county and the county sold the properties at auction in 2014.
Sales produced large surpluses (e.g., Wayside property sold for $206,000 on a $16,750 minimum bid); Plaintiffs sought return of surplus funds, alleging a Fifth Amendment taking without just compensation.
Plaintiffs filed federal suit asserting a Takings Clause claim, § 1983 damages, and a declaratory claim about tolling redemption; they also sought class certification for similarly situated former owners.
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) (lack of subject-matter jurisdiction) and 12(b)(6); the district court dismissed on the merits (12(b)(6)) but denied the jurisdictional challenge.
The Sixth Circuit treated the jurisdictional (12(b)(1)) issue first and held federal courts lack subject-matter jurisdiction because Plaintiffs had adequate state-court remedies and the Tax Injunction Act/comity principles bar federal review.
The Sixth Circuit VACATED the district-court judgment and REMANDED with instructions to DISMISS for lack of subject-matter jurisdiction; Judge Kethledge dissented, arguing federal courts should decide the federal takings claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiffs’ Takings Clause claims are ripe under Williamson County (i.e., whether state remedies must be exhausted)	Plaintiffs said state law (GPTA §211.78l and Court of Claims rules) foreclosed adequate state remedies, so federal forum was proper	Defendants said Plaintiffs could pursue state remedies (inverse condemnation or constitutional challenges) and thus claims are unripe for federal review	Held: Claims unripe—state provided reasonable, certain, adequate remedies; Williamson County requires state-court exhaustion here
Whether GPTA’s §211.78l and Court of Claims jurisdictional scheme bar state-court relief (thus forcing federal forum)	Plaintiffs argued §211.78l and §600.6440 operate so Court of Claims cannot hear constitutional takings claims when a federal remedy exists, leaving no adequate state forum	Defendants argued §211.78l applies narrowly (to notice-based claims) and state circuit courts can hear §1983/takings claims against counties	Held: §211.78l does not bar Plaintiffs; statutory text and avoidance of constitutional conflict show state courts provide a forum (circuit court or Court of Claims where appropriate)
Whether the Tax Injunction Act (TIA) and comity doctrine bar federal jurisdiction over Plaintiffs’ challenges to the tax/foreclosure scheme	Plaintiffs contended TIA/comity did not apply because GPTA foreclosed state remedies	Defendants argued TIA and comity preclude federal injunctive/declaratory relief and bar suits when state courts afford plain, adequate, complete remedies	Held: TIA/comity bar federal adjudication because Michigan courts provide a plain, adequate, complete remedy for the claimed constitutional violations
Proper disposition of the district court judgment	Plaintiffs sought reversal of 12(b)(6) dismissal and continuation in federal court	Defendants cross-appealed jurisdictional denial	Held: Vacated district-court judgment and remanded with instruction to dismiss for lack of subject-matter jurisdiction (no merits decision reached); Kethledge J. dissented

Key Cases Cited

Nat’l Rifle Ass’n of Am. v. Magaw, 132 F.3d 272 (6th Cir.) (Article III cases and controversies ripeness discussion)
Williamson Cty. Reg’l Planning Comm’n v. Hamilton Bank of Johnson City, 473 U.S. 172 (Sup. Ct.) (ripeness rule for takings: final decision and state-court compensation remedies)
Lingle v. Chevron U.S.A. Inc., 544 U.S. 528 (Sup. Ct.) (Takings Clause framed as condition for compensation, not a categorical limitation on regulation)
First English Evangelical Lutheran Church v. County of Los Angeles, 482 U.S. 304 (Sup. Ct.) (damages remedy for takings and availability of post-deprivation compensation)
Haywood v. Drown, 556 U.S. 729 (Sup. Ct.) (state procedural rules cannot be used to undermine federal rights under Supremacy Clause)
Felder v. Casey, 487 U.S. 131 (Sup. Ct.) (state procedures that conflict with federal rights are preempted by Supremacy Clause)
Wilkins v. Daniels, 744 F.3d 409 (6th Cir.) (applying Williamson County framework to takings claims)
Moir v. Greater Cleveland Reg’l Transit Auth., 895 F.2d 266 (6th Cir.) (Rule 12(b)(1) jurisdictional-priority principle)