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    Office of the Circuit Executive 
    U.S. Court of Appeals for the Ninth Circuit 
    
    
    Case Name:
    TAHOE-SIERRA V TAHOE REGIONAL PLANNING AGENCY
    Case Number:
                              Date Filed:
    99-15641
                              10/20/00
    
    
    
    FOR PUBLICATION 
    UNITED STATES COURT OF APPEALS
    FOR THE NINTH CIRCUIT 
    
    
    
    TAHOE-SIERRA PRESERVATION
    
    COUNCIL, INC.; RICHARD A.
    
    ALLISON; ALPINE INVESTMENT
    
    COMPANY, LTD.; AMCO, INC.;
    
    JEFFREY B. ANDERSEN; BETH C.
    
    ANDERSEN; PETER J. ANDERSEN;
    
    JANET I. ANDERSEN; DONALD F.
    
    ARCHIBALD; JEAN L. ATHERTON;
    
    DAVID E. BAKER; MAXINE A.
    
    BAKER; JOHN H. BAKER; PIERINO C.
    
    BARENGO, et al., 
    
    Plaintiff-Appellee-
                                                Nos. 99-15641
    Cross-Appellant, 
                                                99-15771
    v.
                                                D.C. No. CV-84-00257-ECR
    TAHOE REGIONAL PLANNING 
                                                ORDER
    AGENCY, a separate legal entity 
    
    created pursuant to an interstate
    
    compact between the States of
    
    California and Nevada; the voting
    
    members of the governing body of
    
    the Tahoe Regional Planning
    
    Agency including TONY CLARK,
    
    CHESTER A. GIBBS, ALEXANDER
    
    HAAGEN, III, STAN HANSEN,
    
    THOMAS HSIEH, JAMES KING,
    
    ROBERT PRUETT, JAMES S. REED,
    
    LARRY SEVINSON, THOMAS STEWART,
    
    13249
    
    WILLIAM D. SWACKHAMER, PEGGY
    
    TWEDT, RONALD D. WESTERGARD
    
    and NORMAN C. WOODS; STATE OF
    
    CALIFORNIA; STATE OF NEVADA,
    
    Defendant-Appellant- 
    
    Cross-Appellee.
    
    
    
    Filed October 20, 2000 
    
    Before: Henry A. Politz,* Stephen Reinhardt, and
    Michael Daly Hawkins, Circuit Judges.
    
    Order; Dissent by Judge Kozinski
    _________________________________________________________________
    
    ORDER
    
    Judges Politz, Reinhardt, and Hawkins voted to deny the
    petition for rehearing. Judges Reinhardt and Hawkins voted to
    deny the petition for rehearing en banc and Judge Politz rec-
    ommended denial of the petition for rehearing en banc.
    
    A judge of the court called for a vote on the petition for
    rehearing en banc. A vote was taken, and a majority of the
    active judges of the court failed to vote for en banc rehearing.
    Fed. R. App. P. 35(f). 
    
    The petition for rehearing and the petition for rehearing en
    banc are denied. 
    _________________________________________________________________
    *The Honorable Henry A. Politz, Senior United States Circuit Judge for 
    the Fifth Circuit Court of Appeals, sitting by designation.
    
    13250
    
    KOZINSKI , Circuit Judge, with whom Circuit Judges
    O'SCANNLAIN, TROTT, T.G. NELSON and KLEIN-
    FELD join, dissenting from the order denying the petition for
    rehearing en banc: 
    
    The panel does not like the Supreme Court's Takings
    Clause jurisprudence very much, so it reverses First English
    Evangelical Lutheran Church v. County of Los Angeles, 482
    U.S. 304 (1987), and adopts Justice Stevens's First English
    dissent. Because we are not free to rewrite Supreme Court
    precedent, I urged our court to take this case en banc. By vot-
    ing not to rehear, we have neglected our duty and passed the
    burden of correcting our mistake on to a higher authority.
    1. For almost twenty years, Lake Tahoe property owners
    have battled the Tahoe Regional Planning Agency (TRPA),
    which has blocked the owners' efforts to build homes on their
    land. The primary issue on this appeal, the fourth in this inter-
    minable case, is a temporary moratorium that required owners
    to leave their land idle for almost three years. The moratorium
    is only one of a series of restrictions and regulations that have
    prevented the plaintiffs--largely families who purchased lots
    in the 1970s hoping to build vacation or retirement homes--
    from making any use whatsoever of their property. After a
    bench trial, the district court found that the regulation
    deprived the owners of the use of their property for three
    years, and so held they were entitled to compensation. The
    panel does not set aside the lower court's finding. Instead, it
    reverses the judgment because, in its view, a temporary regu-
    lation can never be a regulatory taking.
    
    The government may conscript private property for public
    purposes, but the Fifth Amendment requires that it pay the
    owner for it. See U.S. Const. amend. V ("nor shall private
    property be taken for public use, without just compensation").
    The requirement of just compensation ensures that the few are
    not forced to bear the cost of uses that benefit the many.
    Although a taking is most obvious where the government
    
    13251
    
    directly appropriates the property, physical occupation is not
    necessary. "[W]hile property may be regulated to a certain
    extent, if regulation goes too far it will be recognized as a tak-
    ing." Pennsylvania Coal Co. v. Mahon , 260 U.S. 393, 415
    (1922). The Supreme Court has explained time and again that
    where a regulation deprives the owner of all use and enjoy-
    ment of his property, this amounts to a taking and the govern-
    ment must pay. See Lucas v. South Carolina Coastal Council,
    505 U.S. 1003, 1016 (1992). That's because the "total depri-
    vation of beneficial use is, from the landowner's point of
    view, the equivalent of a physical appropriation. " Id. at 1017. 
    This compensation requirement also guarantees that the gov-
    ernment does not do by regulation what it cannot do through
    eminent domain--i.e., take private property without paying
    for it.
    
    Of course, most land-use regulations are not takings and do
    not call for compensation. A regulation effects a taking only
    where it denies the owner "all economically beneficial or pro-
    ductive use of land." Id. at 1015. Lucas held that a South Car-
    olina agency took two beachfront lots when it promulgated an
    environmental regulation that prevented the owner from
    building on his property. The Court concluded that, when the
    property owner is required "to sacrifice all economically ben- 
    eficial uses in the name of the common good, that is, to leave
    his property economically idle, he has suffered a taking." Id. 
    at 1019. 
    
    The only difference between this case and Lucas is that the
    regulation here had a finite duration. It was originally sup-
    posed to expire after two years and then was extended for
    another eight months. (In fact, its prohibitions continue to this
    day under subsequent development plans.) So the question is
    whether there is something special about a finite moratorium
    that relieves the government from its duty to compensate. The
    Supreme Court answered that question in First English when
    it said that " `temporary' takings which, as here, deny a land-
    owner all use of his property, are not different in kind from
    
    13252
    
    permanent takings, for which the Constitution clearly requires
    compensation." 482 U.S. at 318 (emphasis added).
    
    First English concerned a temporary development morato-
    rium that Los Angeles enacted in response to a flood in the
    Angeles National Forest. First English Church challenged the
    ordinance, which prevented it from rebuilding damaged build-
    ings. The California courts ruled that the regulation could
    only be a taking if permanent; if, on the other hand, the
    county decided to rescind the regulation, it ceased to be a tak-
    ing. The U.S. Supreme Court disagreed, holding that"where
    the government's activities have already worked a taking of
    all use of property, no subsequent action by the government
    can relieve it of the duty to provide compensation for the
    period during which the taking was effective." Id. at 321. 
    
    Justice Stevens dissented from First English because he
    disagreed with the Court's "conclu[sion] that all ordinances
    which would constitute takings if allowed to remain in effect
    permanently, necessarily also constitute takings if they are in
    effect for only a limited period of time." Id. at 322 (Stevens, 
    J., dissenting). Justice Stevens would have held that a tempo-
    rary regulation cannot be a taking, even though it deprives the
    owner of all present uses, because the property retains value
    based upon its future uses. That reasoning, embraced by no
    other member of the Supreme Court, is adopted by the panel
    in this case.
    
    While the opinion nowhere cites Justice Stevens's First
    English dissent, the reasoning--and even the wording--bear
    an uncanny resemblance. Here's why Justice Stevens dis-
    agreed with First English:
    
    Regulations are three dimensional; they have
    depth, width, and length. As for depth, regulations
    define the extent to which the owner may not use the
    property in question. With respect to width, regula-
    tions define the amount of property encompassed by
    
    13253
    
    the restrictions. Finally, and for purposes of this
    case, essentially, regulations set forth the duration of
    the restrictions. It is obvious that no one of these ele-
    ments can be analyzed alone to evaluate the impact
    of a regulation, and hence to determine whether a
    taking has occurred. . . . [I]n assessing the economic
    effect of a regulation, one cannot conduct the inquiry
    without considering the duration of the restriction.
    . . . Why should there be a constitutional distinction
    between a permanent restriction that only reduces
    the economic value of the property by a fraction--
    perhaps one-third--and a restriction that merely
    postpones the development of a property for a frac-
    tion of its useful life--presumably far less than a
    third?
    
    Id. at 330, 332 (Stevens, J., dissenting). And here is the key
    passage of the panel's opinion:
    
    Property interests may have many different
    dimensions. For example, the dimensions of a prop-
    erty interest may include a physical dimension
    (which describes the size and shape of the property
    in question), a functional dimension (which
    describes the extent to which an owner may use or
    dispose of the property in question), and a temporal
    dimension (which describes the duration of the prop-
    erty interest) . . . . A planning regulation that pre-
    vents the development of a parcel for a temporary
    period of time is conceptually no different than a
    land-use restriction that permanently denies all use
    on a discrete portion of property, or that permanently
    restricts a type of use across all of the parcel. Each
    of these three types of regulation will have an impact
    on the parcel's value . . . . There is no plausible basis
    on which to distinguish a similar diminution in value
    that results from a temporary suspension of develop-
    ment.
    
    13254
    
    Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional
    Planning Agency , 216 F.3d 764, 774, 776, 777 (9th Cir. 2000)
    (citation omitted). Although claiming its opinion is fully con-
    sistent with First English, the panel plagiarizes Justice Ste-
    vens's dissent. 
    
    The panel opinion creates a conflict with Tabb Lakes, Ltd.
    v. United States , 10 F.3d 796 (Fed. Cir. 1993), which fol-
    lowed the majority's reasoning in First English . In so doing, 
    Tabb Lakes recognized that "a taking, even for a day, without
    compensation is prohibited by the Constitution." Id. at 800. 
    Under the panel's ruling in our case, a taking for a day could
    never require compensation, because despite the temporary
    deprivation, the property would retain almost all of its value
    based upon its expected future uses.
    
    2. One problem with the panel's theory, and the theory of
    Justice Stevens's dissent, is that it views the regulation's
    effect on a property's value as the taking itself, rather than as
    a test for whether the government has deprived the owner of
    the benefits of his property. A regulation is a taking not
    because it destroys value, but because "total deprivation of
    beneficial use is, from the landowner's point of view, the
    equivalent of a physical appropriation." Lucas, 505 U.S. at 
    1017 (emphasis added). In the case of regulations without a
    sunset provision, the deprivations of value and use are one
    and the same because, where the government permanently
    prevents the owner from putting his property to any beneficial
    use, no potential buyer would offer a dime for it. 1
    
    _________________________________________________________________
    1 In fact, there is no clear-cut distinction between a permanent prohibi- 
    tion and a temporary one. Governmental policy is inherently temporary 
    while land is timeless. Even a permanent prohibition can be rescinded and, 
    in the fullness of time, almost certainly will be. The land may retain mar- 
    ket value based on speculation that it will someday become usable because 
    the regulation will be revoked. See, e.g., Florida Rock Indus., Inc. v.
    United States, 791 F.2d 893, 902 (Fed. Cir. 1986) (recognizing that land 
    might have value under a permanent regulation because a buyer could "bet 
    
    13255
    
    But this identity between value and use obviously does not
    hold true in the case of a temporary taking. The government
    can deprive the owner of all present use, but the property
    might still retain value based upon its future uses. I emphasize
    "might," because so-called temporary moratoria have a habit 
    of living beyond their purported termination dates. In this
    case, a series of consecutive development moratoria has pre-
    vented the landowners from building any homes on their lots
    for the two decades since the start of this litigation. If a local
    government can evade its constitutional obligations by
    describing a regulation as "temporary," we create a sizable 
    loophole to the Takings Clause. Why would a government
    enact a permanent regulation--and risk incurring an obliga-
    tion to compensate--when it can enact one moratorium after
    another, perhaps indefinitely? Under the theory adopted by
    the panel, it's hard to see when a property owner would ever
    state a takings claim against such a scheme.2
    
    Consider also the effect of this theory on non-regulatory
    takings. Let's say the government decides to use your house
    as a warehouse for three years. You are locked out and the
    government has the run of the property for that period. Is
    there any doubt that you have suffered a taking for which you
    should be compensated? Of course not. Why should the case
    be any different if the government simply prohibits you from
    _________________________________________________________________
    
    that the prohibition of rock mining, to protect the overlying wetlands, 
    would some day be lifted"); Florida Rock Indus., Inc. v. United States, 8
    Cl. Ct. 160, 166 n.6 (1985) ("If passively holding land against the possibil-
    ity that restrictions on its use will be lifted were deemed a productive eco- 
    nomic use, property would never be rendered useless by regulation and 
    there could be no such thing as a regulatory taking.").
    
    2 Waiting to see whether a temporary regulation is extended indefinitely 
    will, of course, raise very serious statute of limitations and laches prob- 
    lems. Indeed, in this very case, the panel holds that the statute of limita- 
    tions bars the property owners' challenge to a regulation that succeeded 
    the temporary moratorium (and continues to prevent them from building 
    homes on their property). See Tahoe-Sierra, 216 F.3d at 789.
    
    13256
    
    using your house for three years, but never does get around
    to using it as a warehouse?
    
    Indeed, it's well-established that temporary physical tak-
    ings require compensation. See, e.g., Kimball Laundry Co. v. 
    United States, 338 U.S. 1 (1949); United States v. Petty Motor 
    Co. , 327 U.S. 372 (1946); United States v. General Motors
    Corp. , 323 U.S. 373 (1945). The panel opinion dismisses
    these cases because they involved physical takings, rather
    than regulatory ones. See Tahoe-Sierra, 216 F.3d at 779 ("The
    fact that just compensation was required in these cases, how-
    ever, has no bearing on the question before us."). But First 
    English rejected that distinction and found that these cases
    provided "substantial guidance" for its holding that all tempo- 
    rary takings, including regulatory ones, required compensa-
    tion. 482 U.S. at 318. Again, the panel substitutes its own
    view of takings law for that of the Supreme Court.
    
    These are all big problems with the panel's theory. But, of
    course, the biggest problem is that First English rejected it. 
    First English held that a taking occurs when the government
    deprives an owner of the use of his property, even temporar-
    ily. See 482 U.S. at 318 (" `[T]emporary' takings which, as
    here, deny a landowner all use of his property, are not differ- 
    ent in kind from permanent takings, for which the Constitu-
    tion clearly requires compensation." (emphasis added)); see 
    also Lucas , 505 U.S. at 1033 (Kennedy, J., concurring) ("It is
    well established that temporary takings are as protected by the
    Constitution as are permanent ones."). Nothing in the opinion
    --or any other3 --suggests otherwise. By adopting Justice
    
    _________________________________________________________________
    
    3 The panel cites a pre-First English decision, Agins v. City of Tiburon,
    447 U.S. 255 (1980), as a case that applied the panel's rule against "con- 
    ceptual severance in the temporal dimension." Tahoe-Sierra , 216 F.3d at
    776. But that case is clearly distinguishable. In Agins , the owner sought
    compensation for a taking that never occurred. The city brought a condem- 
    nation proceeding against the owner but subsequently abandoned the suit. 
    The Court rejected the owner's claim that the suit's temporary effect on 
    the value of his property was an action requiring compensation. See Agins ,
    447 U.S. at 263 n.9. That's quite different from a regulation that deprives 
    an owner of all use of his property for a period of time.
    
    13257
    
    Stevens's dissent, the panel places itself in square conflict
    with the majority's opinion in First English.
    
    Of course, the panel doesn't admit that its opinion aligns
    itself with Justice Stevens's dissent, so it must pretend First 
    English said nothing relevant to this case. And so the panel
    does, claiming that First English does not address whether a
    temporary moratorium is a taking, because it was"not even
    a case about what constitutes a taking." Tahoe-Sierra, 216 
    F.3d at 777. It is true that First English did not have to deter- 
    mine whether there was a temporary taking, because it
    accepted the state court's conclusion that a regulation prohib-
    iting all development was a taking while it was in effect. (The
    Supreme Court endorsed that result a few years later in
    Lucas.) But First English did decide that a temporary regula-
    tion is "not different in kind" from a permanent one: If either 
    deprives the owner of all use of his property, then the owner
    is entitled to compensation for the taking. First English, 482 
    U.S. at 318. The panel does not deny that the moratorium
    here, like the regulation in Lucas, deprived the owners of the 
    use of their property for its duration. But it ignores First
    English 's requirement that the owners be compensated for a
    temporary taking. 
    
    The panel also takes shelter from First English in the
    Supreme Court's acknowledgment that it did " `not deal with
    the quite different questions that would arise in the case of
    normal delays in obtaining building permits, changes in zon-
    ing ordinances, variances, and the like which are not before
    us.' " Tahoe-Sierra, 216 F.3d at 778 n.17 (quoting First
    English , 482 U.S. at 321). But that language in First English
    hardly authorizes the panel to ignore the decision altogether.
    Rather, it recognizes that a temporary taking only occurs
    when there is in fact a taking. Delays in obtaining a building
    permit, changes in zoning ordinances, or other temporary
    restrictions will not require compensation unless they deprive
    the landowner of all economically beneficial uses of the prop-
    erty for their duration. Here, the three-year prohibition on
    
    13258
    
    construction does not compare with the inherent delay in
    obtaining a permit or the frictional delay in the permitting
    process. The regulation clearly blocked all construction dur-
    ing the moratorium period.
    
    Justice Holmes noted long ago that "a strong public desire
    to improve the public condition is not enough to warrant
    achieving the desire by a shorter cut than the constitutional
    way of paying for the change." Pennsylvania Coal, 260 U.S. 
    at 416. First English recognized that the costs its decision
    imposed upon local regulators "necessarily flow from any
    decision upholding a claim of constitutional right; many of
    the provisions of the Constitution are designed to limit the
    flexibility and freedom of governmental authorities, and the
    Just Compensation Clause of the Fifth Amendment is one of
    them." First English, 482 U.S. at 321. The panel's desire to
    ease local governance does not justify approving means that
    violate rights secured by the Fifth Amendment as authorita-
    tively interpreted by the Supreme Court.
    

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