Supreme Court Takes Back Takings: Knick v. Township of Scott

Sheppard Mullin Richter & Hampton LLP

Sheppard Mullin Richter & Hampton LLP

The Supreme Court recently issued its long-awaited ruling in Knick v. Township of Scott, concluding that a plaintiff alleging that local governments have violated the Takings Clause under the Fifth Amendment may seek relief directly in federal court, as a constitutional violation occurs at the time of the taking without payment, even if just compensation is subsequently paid.[1] In the 5-4 majority opinion, the Court overruled, in part, Williamson County Regional Planning Comm’n v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), a 34-year old precedent that established a federal claim was not ripe until a state takings plaintiff exhausted its remedies under state law. The decision, among other things, eliminates the “Catch 22” dilemma created by Williamson in which a state judgment denying the takings claim precluded the federal claim from ever becoming ripe because of the preclusive effect of the state judgment under the federal full faith and credit statute (28 U.S.C. §1738). The ramifications of the decision remain to be seen, but property owners will certainly welcome the readier access to the federal courts for takings claims.

In Knick, the Township of Scott, Pennsylvania passed an ordinance requiring that “[a]ll cemeteries … be kept open and accessible to the general public during daylight hours”. The ordinance further defined a “cemetery” as “[a] place or area of ground, whether contained on private or public property, which has been set apart for or otherwise utilized as a burial place for deceased human beings.” Petitioner Knick owned rural property that included a small, private family graveyard. In 2013, the Township notified Knick that she was violating the ordinance. In response, Knick filed suit in state court seeking declaratory and injunctive relief, arguing that the ordinance effected a taking of her property. Knick did not, however, file an inverse condemnation suit under state law to seek compensation for such taking.

The Township withdrew its violation notice and agreed to stay enforcement of the ordinance. Subsequently, the trial court declined to rule on Knick’s declaratory and injunctive relief action, reasoning that without an ongoing enforcement action, Knick could not demonstrate the irreparable harm element necessary for equitable relief. Knick then sought relief in Federal District Court under 42 U.S.C. §1983, alleging that the ordinance violated the Takings Clause of the Fifth Amendment.[2] Citing Williamson County, the District Court dismissed Knick’s claim because she failed to pursue an inverse condemnation action in state court. The Third Circuit Court of Appeals affirmed this ruling, and the Supreme Court granted certiorari to reconsider the holding of Williamson County.[3]

In Williamson County, a property developer filed a claim in federal district court under Section 1983, asserting that the local zoning authority’s rejection of its proposal for a new subdivision after application of various zoning laws and regulations effected a taking of such property. The Supreme Court granted certiorari to address whether the Fifth Amendment entitles a property owner to just compensation when a regulation temporarily deprives him of the use of his property.[4] The Williamson County Court concluded, in relevant part, that state takings plaintiffs were required to exhaust the compensation remedies provided by a state government before the issue was “ripe” for review in federal court.[5]

The Supreme Court advanced several arguments to bolster its conclusion in Knick that the Williamson County state-litigation requirement imposed an unjustifiable burden and conflicted with the Court’s takings jurisprudence. First, the majority stated that the Williamson County holding was not consistent with precedent or workable for litigants, as illuminated by San Remo Hotel, L.P. v. City and County of San Francisco, 545 U.S. 323 (2005). In San Remo Hotel, the plaintiffs complied with the requirements of Williamson County, bringing suit in state court under the Takings Clause of the state constitution and reserving their rights to file a Fifth Amendment claim in federal court if the state suit proved unsuccessful. After losing in state court, the plaintiffs filed suit in federal court, only to discover that their federal claims were barred by the full faith and credit statute, 28 U.S.C. §1738, which required the federal court to give preclusive effect to the state court’s decision. The adverse state court action that gave rise to a ripe federal takings claim under Williamson County simultaneously barred the federal claim.[6] As the Knick Court observed, the “state-litigation requirement relegates the Takings Clause ‘to the status of a poor relation’ among the provisions of the Bill of Rights. Plaintiffs asserting any other constitutional claim are guaranteed a federal forum under §1983, but the state-litigation requirement ‘hand[s] authority over federal takings claims to state courts.’”[7]

The Knick Court further posited that the text of the Takings Clause supported the conclusion that a constitutional violation arises as soon as the government takes private property for public use without paying for it. As the majority pointed out: “The [Takings] Clause provides: ‘[N]or shall private property be taken for public use, without just compensation.’ It does not say: ‘Nor shall private property be taken for public use, without an available procedure that will result in compensation.’”[8] In short, because of the “self-executing character” of the Takings Clause with respect to compensation, a property owner has a Fifth Amendment claim for just compensation at the time of the taking without payment.[9] In other words, the landowner suffers a constitutional violation at the time of the taking without payment, regardless of the availability of a state law remedy to correct the violation.[10] The dissent arrived at the opposite conclusion in reviewing the “spare” text of the Takings Clause, remarking that the Takings Clause does not state, “Nor shall private property be taken for public use, without advance or contemporaneous payment of just compensation, notwithstanding ordinary procedures”; and therefore, interpreting the Takings Clause does not lend itself more persuasively to either Williamson County or the Knick majority.[11] Similarly, the dissent objected to the Court’s contrary position regarding when a Fifth Amendment violation arises, upholding Williamson County’s tenet that “payment need not be paid in advance of or concurrently with a taking as long as ‘reasonable, certain and adequate provision for obtaining compensation’ exist at the time of the taking.”[12]

The Knick Court also found support for its holding in the body of takings jurisprudence, including Jacobs v. United States, 290 U.S. 13 (1933) (allowing a property owner to directly bring a Fifth Amendment claim for compensation upon the taking of the property, without pursuing, for example, the state-litigation requirement as contemplated in Williamson County)[13]; First English Evangelical Lutheran Church of Glendale v. County of Los Angeles, 482 U. S. 304 (1987) (holding that a property owner acquires an irrevocable right to just compensation immediately upon a taking)[14], and a narrower reading of Cherokee Nation v. Southern Kansas R. Co., 135 U. S. 641 (1890). While both the majority and dissent agreed with the holding in Cherokee Nation that a property owner “is entitled to reasonable, certain and adequate provision for obtaining compensation after a taking,” the majority noted the Cherokee Nation line of cases mostly involved claims for injunctive relief because there was no adequate remedy for damages, and against this backdrop interpreted its holding to mean that even though there may be a violation of the Takings Clause (if such compensation was not available at the time of the taking), a property owner is not therefore entitled to injunctive relief when such a reasonable, certain and adequate provision exists.[15] The dissent dismissed the majority’s “creativity”, and outlined its interpretation of these cases to simply demonstrate that the Takings Clause does not demand advance payment, without regard to what kind of relief is requested (injunctive or otherwise).[16]

With respect to whether overruling Williamson County would trample on the doctrine of stare decisis, the majority asserted that (i) the Williamson County reasoning was “exceptionally ill founded” and conflicted with much of the Court’s takings jurisprudence (e.g., Jacobs and First English)[17]; (ii) the state-litigation requirement was originally an element of a takings claim, which became relegated to a “‘prudential’ ripeness rule, and which evolved into other novel theories, thus “undermining the force of stare decisis[18]; (iii) the state-litigation requirement was unworkable in practice, as showcased by the San Remo preclusion trap; and (iv) there are no reliance interests on the state-litigation requirement, effectively “reducing” the force of stare decisis.[19] The dissent cautioned against the majority’s easy dismissal of Williamson County, reminding the Court that purging of precedent demands “a special justification – over and above the belief that the precedent was wrongly decided.”[20] Instead, the dissent asserted Congress can and should resolve the San Remo preclusion trap as evidence that the majority failed to meet this threshold. [21] The dissent further warned that with the Knick ruling, the very routine governmental function of land-use regulation may have the unintended consequence of making government employees carrying out their assigned duties “constitutional malefactors” if such regulations do not provide compensatory remedies upon the taking.”[22] In dismissing this assertion, that majority reasoned that “[its] holding . . . will simply allow into federal court takings claims that otherwise would have been brought as inverse condemnation suits in state court,”[23] and as long as governments provide just compensation remedies “as they have been for nearly 150 years”, federal courts will neither render government regulations invalid as constitutional, nor resort to injunctive relief.[24]

Finally, the dissent admonished that the majority’s holding upsets the balance of judicial federalism by opening the floodgates for all local, state and federal takings plaintiffs to directly bring their claims to federal court, which are not the best suited to handle such claims as the first instance of review.[25] The majority noted, however, that “since the Civil Rights Act of 1871, part of judicial federalism has been the availability of a federal cause of action when a local government violates the Constitution;” this avenue is now provided under Knick. [26]

In sum: with the overturning of the Williamson County state-litigation requirement, if a taking occurs without just compensation, any takings plaintiff (federal state or local) may bring a Fifth Amendment claim in federal court without first exhausting available state and local remedies; a result many property owners nationwide will welcome.

[1] All citations in this post to Rose Mary Knick v. Township of Scott, 588 U.S. ___ (2019) refer to the slip opinion.

[2] Section 1983 provides in relevant part: “Every person who, under color of any statute, ordinance, regulation, custom or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be to the party injured in an action at law[.]”

[3] Knick at 4.

[4] Williamson County at 184.

[5] Id., at 194 (citing Regional Rail Reorganization Act Cases, 419 U.S. 102, 124-125 (1974) and Cherokee Nation v. Southern Kansas R. Co., 135 U.S. 641, 659 (1890)). The Williamson County Court also held that although a regulatory taking was subject to just compensation, such payment need not be paid in advance of or concurrently with a taking as long as ‘reasonable, certain and adequate provision for obtaining compensation’ exist at the time of the taking. Id.

[6] Knick at 6.

[7] Knick at 6.

[8] Knick at 6-7 (analogizing a Fifth Amendment claim against the state under 42 U.S.C. §1983 to a Fifth Amendment claim against the federal government under the Tucker Act, 28 U.S.C. §1491).

[9] Id. at 9.

[10] Id. at 10.

[11] Knick (Kagan, J., dissenting) at 7-8.

[12] Williamson County at 194; see Knick (Kagan, J., dissenting) at 3.

[13] Knick at 8-9.

[14] Knick at 9-10.

[15] Knick at 16.

[16] Knick (Kagan, J., dissenting) at 8-9.

[17] Knick at 20-21.

[18] Id. at 21-22.

[19] Knick at 23.

[20] Knick (Kagan, J., dissenting) at 16.

[21] Knick (Kagan, J., dissenting) at 16.

[22] Id. at 12-13.

[23] Knick at 23.

[24] Id.

[25] Knick (Kagan, J., dissenting) at 15.

[26] Knick at Page 19 n. 8.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sheppard Mullin Richter & Hampton LLP | Attorney Advertising

Written by:

Sheppard Mullin Richter & Hampton LLP

Sheppard Mullin Richter & Hampton LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.