After nearly a decade of conflict, Adam Bros. Farming, Inc.'s quest to receive compensation from the County of Santa Barbara has finally come to an end with a Ninth Circuit ruling in favor of the county.
In 1999 the county had ordered Adams Bros. to cease farming on 95 of its 286 acres near Orcutt because those 95 acres had been designated as wetlands. Adam Bros. originally brought suit in California Superior Court claiming that the wetlands designation was faulty, that it decreased the value and usefulness of their farmland, and that it violated the federal Equal Protection, Due Process and Takings clauses. Adam sought damages and declaratory and injunctive relief.
The Superior Court found the takings claims were not ripe, and Adam amended its complaint to eliminate those claims. At trial, the jury found that the county had in fact conspired to designate a 95 acres as wetlands in an attempt to suppress the value of the land. The court awarded Adam Bros. declaratory and injunctive relief and a jury awarded Adam Bros. $5.6 million in punitive and general damages (CP&DR Vol. 20, No. 1).
The county then appealed, and the appellate court eliminated the damages. It did, however, uphold the declaratory and injunctive relief, holding that the wetlands delineation was contrary to law.
In an effort to obtain compensation from the county, Adam Bros. then went to federal court alleging violations of the federal Takings Clause. Adam Bros. lost at the district court based on procedural issues and appealed. The Ninth Circuit Court of Appeal also ruled against Adam based on procedural issues in this case, thus effectively exhausting Adam Bros.'s legal options.
According to the Ninth Circuit, Adam Bros.'s takings claim was barred by the doctrine of res judicata. Res judicata bars a plaintiff from re-adjudicating claims that have already been decided by another court. In this case, the Ninth Circuit found that the claims adjudicated by the state court involved the same underlying facts, and the fact that Adam decided to amend its complaint by eliminating the takings claims did not bar the application of res judicata to those claims. Therefore, Adam will not be receiving compensation for the county's faulty wetlands delineation.
Adam Bros. Farming, Inc. v. County of Santa Barbara (2010) 604 F.3d 1142
For Adams Bros.: J. David Breemer, Pacific Legal Foundation
For Santa Barbara County: Lisa A. Rothstein, Deputy County Counsel
Cori M. Badgley is an attorney with the firm of Abbott and Kindermann, LLP.