Whether a property owner can pursue a 42 USC §1983 claim and constitutional takings claim in federal court after state court proceedings involving alleged due process violations and political interference with building permits

This Petition raises several questions of federal law: Wh e re a p ro pe rty o wn e r has i ts b uil din g pe rmi ts revoked by a government agency on false pretenses and in violation of state Due Process law, is that property owner entitled to have its 42 USC §1983 claim for relief and its claim for relief that its property was an illegal taking in violation of the United States Constitution heard in federal court? Where a federal district court judge abstains from hearing the matter under the Pullman abstention doctrine, and sends the matter to state court is the plaintiff forever barred from returning to federal court even though it was denied a full and fair hearing in state court judicial proceedings? Where the state court judge denies a federal plaintiff the right to perform discovery, to admit highly relevant evidence of the government’s wrongful revocation of its building permits does federal law still hold that the plaintiff had a full and fair hearing to deny its right to have its case tried in federal court? Where very high powered national and local politicians contact the administrative board behind the scenes to revoke the building permits sufficient to prove that the property owner was denied its right to build the property it had earlier been approved to build? Is the England res e rv a ti o n mad e b y P lain tiff in state court the permissible manner to protect its rights to return to federal court contrary to the Ninth Circuit opinion? ii THE PARTIES The parties are Sullivan Equity Partners, LLC, a Delaware limited liability company and the City of Los Angeles is the Respondent. iii CORPORATE DISCLOSURE REQUIREMENT Petitioner is a Delaware limited liability company. No publicly held company owns 10% or more of its stock, and it has no parent company. iv RELATED CASES STATEMENT • Sullivan Equity Partners, LLC v. City of Los Angeles, 24-2893, U.S. Court of Appeals for the Ninth Circuit, judgment issued March 10, 2025, order denying rehearing issued April 18, 2025. • Sullivan Equity Partners, LLC v. City of Los Angeles, 2:16-cv-07148-CAS, U.S. District Court for the Central District of California, judgment issued April 11, 2024.