By Cori Badgley
In 2004, a jury awarded Adam Bros. Farming, Inc. (“ABFI”) over $5 million in civil damages. The trial court assessed these damages against individual County officials as well as the County of Santa Barbara (“County”). On March 4, 2008, the Court of Appeal, Second Appellate District overturned the award of damages in an unpublished opinion, Adam Bros. Farming, Inc. v. County of Santa Barbara (Docket No. B180880, 2008). The appellate court held that Adam Bros. Farming, Inc. lacked standing to bring its constitutional claims and the claims were barred by the statute of limitations. Therefore, the civil damages had to be overturned.
The facts of the case involved a determination by the County that a 95-acre segment of land was wetlands. Following this determination, the Adam family purchased property that included the area delineated. The Adam family planned to farm the land through its corporation, ABFI. ABFI asserted that the facts supporting the wetland delineation had been falsified, and this falsification violated their substantive due process rights as well as their equal protection rights. The jury found that the property had been improperly delineated as wetlands and awarded ABFI the unprecedented amount of more than $5 million in damages. Part of these damages were imposed on individual County officials involved in the wetland delineation. County officials are rarely found individually liable for their actions. The County and other defendants filed an appeal.
The two main issues that the Court of Appeal faced were 1) whether ABFI lacked standing to bring its constitutional claims, and 2) whether the one-year statute of limitations for constitutional claims had lapsed before ABFI brought suit.
According to the County, ABFI did not own the property when the wetland delineation occurred, and therefore, it lacked standing to bring the constitutional claims. The Court of Appeal agreed. The court stated that “there is no section 1983 claim unless a plaintiff is deprived of a property interest plaintiff held at the time the government misconduct occurs.” Since ABFI and the Adam family did not own the property when the County delineated the wetlands, ABFI lacked standing to bring the constitutional claims under Title 42 United States Code section 1983.
The court also found that the statute of limitations had lapsed by the time ABFI filed the lawsuit against the County. The jury had found that ABFI did not know about the constitutional violation until March 1999, and the lawsuit was filed in 2000. Agreeing with the County, the court found that substantial evidence did not support the jury’s finding, and ABFI must have discovered the violation no later than July 1998. The court stated that shortly after the Adam family bought the property, the family knew about the wetland delineation. The court also stated ABFI admitted that it “quickly concluded that the wetland delineation was contrary to the facts.” The Adam family acquired the property in November 1997. The court concluded that ABFI must have known about the constitutional violation by July 1998, and therefore, the statute of limitations barred ABFI’s constitutional claims.
In light of the court’s ruling on the standing issue and the statute of limitations issue, the civil damages award was overturned. However, the declaratory and injunctive relief was upheld by the appellate court, which means that the wetland delineation is still invalid and ABFI can, with the proper permits, farm the property. Although the damages award was overturned in this case, individual officials may still be held individually liable for their actions in certain circumstances. (See Johnson v. City of Pacific (1970) 4 Cal.App.3d 82.)
Cori Badgley is an associate with Abbott & Kindermann, LLP. For questions relating to this article or any other California land use, environmental and planning issues contact Abbott & Kindermann at (916) 456-9595.
The information presented in this article should not be construed to be formal legal advice by Abbott & Kindermann, LLP, nor the formation of a lawyer/client relationship. Because of the changing nature of this area of the law and the importance of individual facts, readers are encouraged to seek independent counsel for advice regarding their individual legal issues.