Narrative Opinion Summary
The case involves a dispute wherein plaintiffs, including an individual and a corporation, Marine One, Inc., filed a lawsuit against a Florida county and its board of commissioners under 42 U.S.C.A. § 1983. They alleged the rescission of marina construction permits deprived them of a property interest and violated their substantive due process rights. The district court directed a verdict for the defendants, finding no protectable property interest. The plaintiffs operated a marina from 1982 to 1985 and sought to build another, requiring specific permits. Complaints about obstruction led the county to rescind permits after a hearing. The plaintiffs did not pursue injunctive relief and ceased operations. A jury initially awarded damages, but the court overturned this, citing lack of a cognizable property interest. On appeal, plaintiffs argued for a vested right under Florida law through equitable estoppel, but the court found no such right existed. It affirmed that monetary damages are unavailable for permit rescission, and only equitable remedies apply. The court upheld the dismissal of the plaintiffs' claims, affirming no deprivation of a protected property interest occurred, rendering defendants' cross-appeal moot.
Legal Issues Addressed
Equitable Estoppel in Permit Revocationsubscribe to see similar legal issues
Application: The court considered whether the plaintiffs could claim a vested property right under Florida law based on equitable estoppel due to reliance on the issued permits.
Reasoning: Schmidt argues that his reliance on the permit grants him a vested property right, supported by equitable estoppel under Florida law. He cites Florida cases suggesting a property owner gains a vested interest if a governmental entity is equitably estopped from altering previously permitted development.
Property Interest under 42 U.S.C.A. § 1983subscribe to see similar legal issues
Application: The court examined whether the rescission of marina construction permits deprived the plaintiffs of a federally protected property interest under 42 U.S.C.A. § 1983.
Reasoning: The district court directed a verdict against Marine One and upheld a judgment for the defendants, despite a jury awarding Schmidt $1,010,000 in damages. The court affirmed that neither Schmidt nor Marine One possessed a protectable property interest in the permits.
Remedies for Permit Revocation under Florida Lawsubscribe to see similar legal issues
Application: The court found that monetary damages are not available in Florida for the rescission of a permit and that the proper remedy is to challenge the validity or invoke equitable estoppel.
Reasoning: Florida law does not allow for monetary damages from rescinding a permit; rather, the sole remedy is to challenge the validity of the zoning ordinance or to invoke equitable estoppel if conditions are met.
Substantive Due Process under the Fourteenth Amendmentsubscribe to see similar legal issues
Application: Plaintiffs claimed that the rescission of permits violated their substantive due process rights under the Fourteenth Amendment.
Reasoning: Schmidt and Marine One appeal, claiming the County's revocation of the building permit violated the Fifth Amendment's prohibition against taking private property without just compensation and the Fourteenth Amendment's substantive due process requirement.