No. 25-1078

Natural Lands, LLC v. City of Boca Raton, Florida, et al.

Lower Court: Eleventh Circuit
Docketed: 2026-03-12
Status: Pending
Type: Paid
Response Waived
Tags: due-process-clause explicit-bias procedural-due-process property-rights section-1983 variance-application
Latest Conference: N/A
Question Presented (from Petition)

Natural Lands, LLC, purchased an undeveloped beachfront lot in Palm Beach County, Florida, which was zoned for residential development and "grand fathered " with a vested right to build a single -family home, subject to certain variance requirements. During a lengthy process to secure building approval, three future City Council members campaigned on promises to deny all development on Natural Lands ' property. When the Council finally scheduled a hearing on its application for a construction variance , Natural Lands requested recusal of these now -elected member s. But the Council refused , held the hearing, and denied the application. After a bench trial, the district court held that "the explicit bias of the three Council Members against any development on the parcel tainted the vote on Plaintiff 's variance application " and violated the Due Process Clause. The Eleventh Circuit reversed, holding , in conflict with other Circuits , that the existence of state court remedies barred Natural Lands' due process claim in federal court .

Whether the availability of state remedies bars a property owner from seeking relief from a due process violation in federal court pursuant to 42 U.S.C. § 1983?

Question Presented (AI Summary)

Whether the availability of state remedies bars a property owner from seeking relief from a due process violation in federal court pursuant to 42 U.S.C. § 1983?

Docket Entries

2026-04-08
Waiver of Boca Raton Beach and Park District of right to respond submitted.
2026-04-08
Waiver of right of respondent Boca Raton Beach and Park District to respond filed.
2026-03-25
Motion to extend the time to file a response is granted and the time is extended to and including May 13, 2026.
2026-03-24
Motion of City of Boca Raton for an extension of time submitted.
2026-03-24
Motion to extend the time to file a response from April 13, 2026 to May 13, 2026, submitted to The Clerk.
2026-03-10
Petition for a writ of certiorari filed. (Response due April 13, 2026)
2026-01-14
Application (25A815) granted by Justice Thomas extending the time to file until March 17, 2026.
2026-01-09
Application (25A815) to extend the time to file a petition for a writ of certiorari from February 15, 2026 to March 19, 2026, submitted to Justice Thomas.

Attorneys

Boca Raton Beach and Park District
Jeffrey Lawrence HochmanJohnson, Anselmo et al, Respondent
City of Boca Raton
Laura Keats WendellWeiss Serota Helfman Cole & Bierman, P.L., Respondent
Natural Lands, LLC
J. David BreemerPacific Legal Foundation, Petitioner