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department of real property & land use

When the asset is land, and the clock is the injury.

Regulatory takings, entitlement delay and unbuilt projects each carry a different measure. Using one number for all three is the characteristic error in this field.

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Cournotreal property & land use · a diagnostic, not a damages opinion
Tell me about the property, what was prevented, and over what period. I'll help you see which measures each theory carries and what each would demand in records. I won't value the property or tell you what the matter is worth.

Real property disputes produce a damages problem with a distinctive shape. The asset does not disappear; it sits there, often appreciating, while its owner is prevented from doing something with it. The injury is therefore usually a period rather than a destruction, and the measure has to price time rather than value a thing. That single feature explains most of what goes wrong here. A landowner denied approval for two years has not lost the land, and has frequently not lost its value either, so a claim built as though the property were destroyed will be met with the observation that the owner still owns it and it is worth more than when the dispute began. What the owner has lost is the use of the property during the period, the money spent carrying it while nothing could be built, and, if the evidence will support it, the profit on a project whose timing was pushed. Those are three different measures with three different evidentiary demands, and the law attaches them to different theories: a temporary regulatory taking is generally measured by the return on, or the rental value of, the property during the taking period; consequential delay damages are the costs actually incurred; lost development profit is a projection of a business that never operated. They are not interchangeable, they are not additive without care, and the most common error in this field is a single figure asserted across all of them. A second error follows close behind: gross revenue offered as a damages figure. Revenue is not a measure under any of these theories, because it ignores every cost that would have been incurred to earn it, and an income capitalization approach with cap rates and rent comps presumes a stabilized income-producing asset, which is simply the wrong instrument if the units were underwritten for sale rather than to hold. Meanwhile the component most often missing is the one most defensible: construction cost escalation across the delay period, measured against published indices rather than asserted, is frequently the largest thing a delayed developer can actually prove. Entitlement to any of these measures, and which theory supports which, is a question of law for counsel; what follows is what each requires in evidence and where each is attacked.

specialization areas

Areas in this part of the practice.

Three measures, three evidentiary problems, and a strong tendency to be collapsed into one.

methodology

How this department investigates.

How the Institute approaches a land use damages question.

Separate the theories firstBefore any number, establish which measure attaches to which claim, because a single figure spread across all of them is the standard defect here.
Define the period preciselyWhen the clock started and what ends it. Almost every measure in this area is a function of the period rather than of the asset.
Start from costs actually incurredCarrying costs are documented, provable and rarely disputed in existence. They are the floor an opinion should build from.
Escalation against published indicesConstruction cost movement over the delay is measurable from published series rather than asserted, and is often the largest defensible component.
common questions

Land and entitlement: the questions counsel ask.

Our client valued the claim with an income approach and cap rates. Is that right?

It depends entirely on what the project was going to be, and it is the first thing a defense expert will test. An income capitalization approach values a stabilized income-producing asset by capitalizing the rent it throws off in perpetuity. That instrument fits a build-to-hold rental project. It does not fit for-sale product, where the developer builds, sells and exits, and where the economics are a development margin over a defined period rather than a perpetual income stream. Many mixed projects are part sale and part hold, and applying cap rate machinery across the whole of one is a visible error. Separately, and regardless of the instrument, a gross revenue figure is not a damages figure under any theory in this area: the construction, financing, marketing, sales and carrying costs that would have been incurred to earn that revenue come out of it, and the absence of that deduction is the easiest thing in the case to attack.

What is actually measured in a temporary regulatory taking?

Generally the return on, or the rental value of, the property during the period of the taking, rather than the profit on a development that was never built. The intuition is that the owner was deprived of the use of the property for a period, so the compensation looks like what the use of that property was worth over that period, often expressed as a market rate of return applied to the property value or as the fair rental value of the land in the condition it was in. This is a materially different, and usually smaller, figure than a development profit projection, which is why the distinction matters so much: a claim that presents lost development profit as the taking measure has not merely overstated the number, it has answered a different question from the one the theory asks. Whether the theory is available at all, what period counts, and which measure a court will apply are questions of law and vary; that boundary belongs to counsel.

Why is lost profit on an unbuilt project the hardest measure?

Because every link in the chain is a projection about a business that never operated. The project was never financed, never built, never leased or sold, and often never fully designed, so the expert has to establish that it would have been approved, that financing was actually available on the terms assumed, that construction would have completed on the assumed schedule and budget, and that the finished units would have sold or leased at the assumed prices into the market as it actually turned out. Each link invites the speculative profit objection, and courts in many jurisdictions treat unbuilt-project profits with particular caution for exactly that reason. It is not always unavailable, and a developer with a track record of comparable completed projects, committed financing and pre-sales stands in a far stronger position than a first-time applicant with a concept. But it is the measure most likely to be excluded, and building the case on it alone, when carrying costs and escalation are provable, is a strategic error as well as an evidentiary one.

What gets left out of these claims most often?

Construction cost escalation across the delay period. It is measurable against published cost indices rather than asserted, it is often large over a multi-year delay in a market where construction costs moved sharply, and it is unusually defensible because it does not require any projection of a business that never operated: it is the difference between what the work would have cost then and what it costs now. Interest and carrying costs on land debt are the second omission, and the third is the professional fee stack, the architects, engineers, consultants and counsel who had to stay engaged while the clock ran. These are documented, provable and rarely disputed in existence, which makes them the floor an opinion should build from before it reaches for anything requiring a projection.

Land use damages, sorted by theory.

Describe the property, the period and the claims. The Institute will help you see which measures the facts can actually support.

Cournotdiagnostic · not a damages opinion
Tell me about the property, what was prevented, and over what period. I'll help you see which measures each theory carries and what each would demand in records. I won't value the property or tell you what the matter is worth.