What is the question presented in Pakdel v. City and County of San Francisco?

1. Can a takings plaintiff establish ripeness under Williamson County’s final decision rule where the local land use authority issued its final decision on a different project, before plaintiff refused to comply with and belatedly sought relief from a condition of project approval? 2. Does the unconstitutional conditions doctrine apply to a legislative condition imposed on every subdivision map issued through an expedited processing program in exchange for a fee refund, expedited processing of the map, increased property value, and other tangible benefits granted to all participating property owners?

What is Pakdel v. City and County of San Francisco about?

This case arose after San Francisco required the owners of a unit in a building being converted to condominiums to offer their tenant a lifetime lease, and the owners claimed that condition amounted to an unconstitutional taking of their property. The Supreme Court considered whether their federal takings claim was ready to be heard once the city had definitively denied them an exemption, or whether they first had to keep pursuing additional local administrative procedures.

When did the Supreme Court decide Pakdel v. City and County of San Francisco?

The Supreme Court decided Pakdel v. City and County of San Francisco on June 28, 2021.

No. 20-1212October Term 2020Decided Jun 28, 2021Updated Sep 3, 2026

Docket 20-1212October Term 2020 (2020–2021)

Pakdel v. City and County of San Francisco

Pakdel concerned whether owners challenging San Francisco's lifetime-lease condition had done enough locally to bring a federal takings claim.

Case status

Decided · June 28, 2021

Read the opinion (PDF)

Current stage: Decided
Latest event: Decision released Jun 28, 2021

Case Accepted

Arguments

Decision ReleasedJun 28, 2021

What it's about: This case arose after San Francisco required the owners of a unit in a building being converted to condominiums to offer their tenant a lifetime lease, and the owners claimed that condition amounted to an unconstitutional taking of their property. The Supreme Court considered whether their federal takings claim was ready to be heard once the city had definitively denied them an exemption, or whether they first had to keep pursuing additional local administrative procedures.
Question presented
1. Can a takings plaintiff establish ripeness under Williamson County’s final decision rule where the local land use authority issued its final decision on a different project, before plaintiff refused to comply with and belatedly sought relief from a condition of project approval? 2. Does the unconstitutional conditions doctrine apply to a legislative condition imposed on every subdivision map issued through an expedited processing program in exchange for a fee refund, expedited processing of the map, increased property value, and other tangible benefits granted to all participating property owners?
Case path: United States Court of Appeals for the Ninth Circuit / Decision released Jun 28, 2021
Area: Decided Supreme Court case

Decision

Decision recordJun 28, 2021

What the Court decided

Pakdel concerned whether owners challenging San Francisco's lifetime-lease condition had done enough locally to bring a federal takings claim.

Impact

The dispute affects property owners and cities when land-use approvals come with conditions. For example, an owner denied an exemption may need to know whether a federal court can hear the claim immediately or only after further local procedures.

Not official Court text.

Opinion documents

Opinion

Briefing

What it's about

The case concerned San Francisco's requirement that condominium-conversion owners offer a tenant a lifetime lease. The owners said the condition was an unconstitutional taking and argued their federal claim was ready after the city denied an exemption.

Impact

The dispute affects property owners and cities when land-use approvals come with conditions. For example, an owner denied an exemption may need to know whether a federal court can hear the claim immediately or only after further local procedures.

What's next

The Supreme Court has finished this docket action. Any further proceedings would follow the Court's completed action in the case.

What was the dispute in Pakdel v. City and County of San Francisco?

Owners challenged a requirement to offer their tenant a lifetime lease during a condominium conversion. They said it unconstitutionally took their property.

Who could be affected by the Pakdel case?

Property owners facing conditions on local approvals and cities imposing those conditions could be affected. The case concerns when an owner may bring a federal claim.

What happens next in Pakdel v. City and County of San Francisco?

The Supreme Court has completed its docket action. Further steps, if any, would occur in proceedings after that action.

Timing

Decided June 28, 2021

The Court released its decision on June 28, 2021 without hearing oral argument.

Argument and decision days

Documents

Opinions

Opinion

Key filings

Petition

Briefs on file: 6View on supremecourt.gov

View full docket on supremecourt.gov

Activity

Docket activity3

AI analysis generated: Case Briefing
Sep 3, 2026 | Generated
Opinion added: opinion
Jun 28, 2021 | Court records
Brief added: Petition
Feb 26, 2021 | Court records

Related cases

Illustration for Mujera Benjamin Lung'aho v. United States

Docket 25-6124Mujera Benjamin Lung'aho v. United StatesDecided Jun 30, 2026

Illustration for Learning Resources, Inc., et al., Petitioners v. Donald J. Trump, President of the United States, et al.

Docket 24-1287Learning Resources, Inc., et al., Petitioners v. Donald J. Trump, President of the United States, et al.Decided Feb 20, 2026

Illustration for Okello T. Chatrie, Petitioner v. United States

Docket 25-112Okello T. Chatrie, Petitioner v. United StatesDecided Jun 29, 2026

Illustration for Donald J. Trump, President of the United States, Applicant v. Lisa D. Cook, Member of the Board of Governors of the Federal Reserve System

Docket 25A312Donald J. Trump, President of the United States, Applicant v. Lisa D. Cook, Member of the Board of Governors of the Federal Reserve SystemDecided Jun 29, 2026

View the full docket

Grounding

Grounding: Primary materials plus reporting.
Note: Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked: Sep 3, 2026
Method: Methodology

Primary materials8

Context reporting4