Williamson County Regional Planning Commission V. Hamilton Bank of Johnson City - Subsequent History

Subsequent History

In San Remo Hotel v. City and County of San Francisco, a majority of the Court held that the Full Faith and Credit Statute bars relitigating a Fifth Amendment takings claim in federal court, after just compensation has been denied in state court proceedings. This seemed to bear out the views of commentators who saw Williamson County's second prong as extinguishing federal takings claims, rather than ripening them. Writing for a four-justice concurrence, Chief Justice Rehnquist noted that the impact of the Court's holding could preclude aggrieved property owners from having their federal takings claim considered by any court, and called for the Court to reconsider Williamson County's state procedures doctrine "in an appropriate case." Although the issue has been presented in several petitions for certiorari since then, however, the Roberts Court has denied certiorari and has shown no interest in pursuing the late Chief Justice's proposal.