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

Natural Lands, LLC, purchased an undeveloped beachfront lot in Palm Beach County, Florida, which was zoned for residential development and “grandfathered” 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 members. 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. The question presented is: 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?