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Goodwin v. Walton County Florida

Citations: 248 F. Supp. 3d 1257; 2017 U.S. Dist. LEXIS 49681Docket: Case No. 3:16-cv-364/MCR/CJK

Court: District Court, N.D. Florida; March 31, 2017; Federal District Court

Narrative Opinion Summary

In this case, plaintiffs challenged two ordinances enacted by Walton County, Florida, claiming constitutional violations, including a First Amendment issue with a sign ordinance and a Fifth Amendment takings claim against a Customary Use Ordinance. The Customary Use Ordinance, effective April 1, 2017, allowed public recreational use of dry sand beach areas, prompting the Goodwins to argue it constituted a per se physical taking of their property. The county's motion to dismiss these claims was denied by the court, which found the facial takings claim ripe, despite the ordinance's future effective date. The plaintiffs sought a preliminary injunction to prevent the ordinance's enforcement, but the court denied this request, ruling that they failed to show irreparable harm or that the balance of harms favored them over the public interest. The court highlighted that facial challenges to takings are immediately ripe, unlike as-applied challenges that require economic impact assessment. As a result, the case will proceed, with discovery allowed to continue for 45 days. The court's decision underscores the complexity of takings law and the rigorous standards required for preliminary injunctive relief.

Legal Issues Addressed

Facial vs. As-Applied Challenges in Takings Claims

Application: The Court emphasized that facial challenges are ripe upon passage of an ordinance, unlike as-applied challenges which require specific economic impact considerations.

Reasoning: The Court also addresses the ripeness of the Goodwins' claim under the Williamson County doctrine, stating that it does not apply to facial challenges, which are considered ripe upon the passage of the relevant ordinance.

First Amendment Violation in Sign Ordinance

Application: Plaintiffs claimed a First Amendment violation related to a sign ordinance, leading to the county consenting to a preliminary injunction against it.

Reasoning: The county consented to a preliminary injunction against the sign ordinance while the case proceeded.

Preliminary Injunction Requirements

Application: The Court denied the preliminary injunction as the Goodwins failed to demonstrate irreparable harm and a favorable balance of harms against the public interest.

Reasoning: A preliminary injunction is recognized as an extraordinary remedy requiring the movant to satisfy all four elements to warrant its issuance.

Ripeness Doctrine and Facial Claims

Application: The Court found the Goodwins' facial takings claim ripe despite the ordinance not being effective, as facial challenges are exceptions to the compensation requirement.

Reasoning: The Court recognizes a tension in declaring the facial challenge ripe without just compensation being sought, emphasizing that facial takings claims are a unique exception to the compensation requirement.

Takings Clause under the Fifth Amendment

Application: The Goodwins amended their complaint to include a Fifth Amendment taking claim against the Customary Use Ordinance, asserting it constituted a per se physical taking of their property.

Reasoning: The Goodwins contend that the County's Customary Use Ordinance constitutes a per se physical taking of their property, diverging from the usual 'as-applied' challenge.