Montclair Parkowners Ass'n v. City of Montclair

We must decide whether the Younger abstention doctrine requires the dismissal of a federal lawsuit brought to vindicate rights under the Takings Clause of the federal Constitution because the plaintiffs analogous claims under state law were proceeding before a state court at the same time that the plaintiffs federal claim was to be considered by the federal court.

I

In July 1998, the City of Montclair, California, (“Montclair”) adopted Ordinance number 98-777, a rent-control provision regulating trailer parks. The ordinance prohibits a trailer park owner from increasing the rent for trailer spaces in his park upon their sale or transfer by more than the greater of three percent or the latest annual percentage increase in the consumer price index (up to eight percent). Park owners may apply, however, for administrative permits under the ordinance to increase prices for the purpose of recovering certain increased costs.

On August 17, 1998, the Montclair Par-kowners Association and Hacienda Mobile Home Estates (collectively, “the Association”) brought suit in federal district court for the Central District of California pursuant to 42 U.S.C. § 1988 . The Association alleged that…