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Tilem v. City of Los Angeles

Citations: 142 Cal. App. 3d 694; 191 Cal. Rptr. 229; 1983 Cal. App. LEXIS 1676Docket: Civ. 64576

Court: California Court of Appeal; May 5, 1983; California; State Appellate Court

Narrative Opinion Summary

The case involves eminent domain proceedings initiated by the City of Los Angeles against properties owned by a landowner, which were later abandoned, leading to a legal dispute over inverse condemnation. The landowner filed for damages, claiming that the City's precondemnation activities significantly devalued his property, particularly affecting his ability to develop and market the land. The court found the City's conduct unreasonable and in violation of statutory duties, such as failing to consider severance damages. The trial was bifurcated into legal and valuation phases, ultimately resulting in partial damages awarded to the landowner for one parcel, while denying damages for another, due to differing views on whether a lease-option agreement constituted a sale. On appeal, the court upheld the trial's liability findings, but remanded for further assessment of damages and litigation costs, emphasizing the broad interpretation of 'taking' and 'damaging' under the California Constitution. The case underscores the legal principles surrounding eminent domain, inverse condemnation, and the importance of reasonable governmental conduct in property acquisition processes.

Legal Issues Addressed

Attorney Fees and Litigation Costs in Condemnation Actions

Application: Tilem was awarded attorney fees and costs, though the court remanded for reassessment due to unclear allocations.

Reasoning: The trial court awarded $15,000 in attorney fees and $8,421.62 in other litigation expenses.

Definition of 'Taking' and 'Damaging' under California Constitution

Application: The court interpreted 'taking' and 'damaging' broadly, emphasizing impacts on property rights.

Reasoning: Under California Constitution, article I, section 19, compensation is mandated for property that has been 'taken or damaged.'

Eminent Domain and Inverse Condemnation

Application: The City of Los Angeles initiated eminent domain proceedings, but the subsequent abandonment led to a focus on Tilem's inverse condemnation claim.

Reasoning: In February 1978, the City of Los Angeles initiated eminent domain proceedings against a portion of two parcels owned by Joseph Tilem. Tilem was not served until June 1978, at which point he filed a separate action for inverse condemnation and damages.

Government Code Section 7267 and Severance Damages

Application: The City failed to consider severance damages, violating statutory obligations.

Reasoning: The court found the City's offer of compensation and refusal to consider severance damages were deemed unreasonable, constituting a breach of statutory duty under Government Code section 7267 et seq.

Precondemnation Damages under Klopping v. City of Whittier

Application: The trial court found that the City's precondemnation activities significantly devalued Tilem's property, warranting damages.

Reasoning: On September 26, 1979, Judge Woods found that the City's precondemnation conduct significantly hindered Tilem's ability to use and sell the property at fair market value.