In the 1984 case Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, the U.S Supreme Court ruled that a property owner must first exhaust all state court remedies before filing a federal claim for compensation due to an alleged violation of Fifth Amendment rights by local zoning laws. The bank had sued after its development plans were rejected by the planning commission, claiming it was denied economically viable use of its land without just compensation. However, the Supreme Court held that since Tennessee law allowed suits against municipalities for damages resulting from regulations affecting real estate values and no such suit had been filed in state court yet, there was no final decision on whether or not they would be compensated and thus their claim wasn't ripe for review in federal courts. This ruling established what is known as "Williamson County ripeness doctrine", which has significant implications on where takings claims can be brought.

In the dissenting opinion for Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, Justice John Paul Stevens argued that the majority's decision to require property owners to exhaust state remedies before filing a federal takings claim was unnecessary and overly burdensome. He contended that this requirement would force property owners into lengthy and expensive litigation in state courts before they could seek relief in federal court, even when their claims were based on violations of federal law. Furthermore, he expressed concern that this approach might discourage individuals from pursuing valid constitutional claims due to the financial burden and delay associated with navigating two separate legal systems. In his view, it was more appropriate for these cases to be heard directly by federal courts as they inherently involve questions of constitutional law.