In the case of Pakdel v. City and County of San Francisco, Peyman Pakdel and Sima Chegini challenged a city ordinance requiring owners who convert rental properties into tenancy-in-common arrangements to offer lifetime leases to existing tenants. The couple argued that this violated their Fifth Amendment rights against government taking private property without just compensation. They had planned on eventually moving into the unit they owned in a six-unit building but were told by the city they needed to offer their tenant a lifetime lease first, which would effectively prevent them from ever living there themselves. However, both district court and Ninth Circuit Court rejected their claims stating that it was not ripe for adjudication because they hadn't sought compensation through state procedures first before filing federal suit - an argument known as "Williamson County ripeness". In 2020, Supreme Court vacated these decisions instructing lower courts to reconsider whether plaintiffs can bypass seeking state remedies if facing undue burden.

In the dissenting opinion for Pakdel v. City and County of San Francisco, 2020, Justice Sonia Sotomayor argued that the court should not have granted review in this case because it did not meet the criteria for a "ripe" dispute. She pointed out that plaintiffs had an opportunity to seek compensation through state procedures but chose not to do so before filing their federal claim. This is significant as it goes against precedent set by Williamson County Regional Planning Commission v Hamilton Bank of Johnson City (1985), which requires property owners to use available state procedures before they can bring a federal takings claim under Fifth Amendment. The majority's decision effectively overruled this requirement without any explanation or justification, according to her view.