Santa Fe Land Improvement Co. v. City of Chula Vista

This case presents the question whether a District Court may abstain from the exercise of jurisdiction in an action for inverse condemnation, challenging the authority of a municipality to rezone lands specified for industrial use to a designation of open *574 space. Because the federal constitutional issues raised might be mooted by a state court determination of applicable state law, and because the case presents difficult and significant questions of uncertain state law, the court defers to the state courts and declines the role of a beacon light in the uncharted waters of California land use law. The courts of the State of California are competent to be the initial interpreters of their own statutory program of land use. The court would therefore abstain from the exercise of jurisdiction.

Plaintiff Santa Fe Land Improvement Company (hereinafter “Santa Fe”) owns two parcels of realty totaling 352.06 acres in the Bay Front area of Chula Vista. It alleges that it acquired the realty in the 1930’s for industrial usage, for which the property was then zoned; but no industrial use was effected during the succeeding three decades. In January 1971 defendant City of Chula…