Jardin de las Catalinas Ltd. P’ship v. Joyner, No. 12-1757 (1st Cir. 2014)
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Plaintiffs, two limited partnerships, each owned an apartment building in Puerto Rico that qualified for low-income housing tax credits. Defendant was the agency responsible for allocating the credits. Plaintiffs and Defendant entered into agreements setting the applicable percentage for their covered projects at 8.12 percent. Thereafter, Congress passed legislation providing that the applicable percentage for developments such as those owned by Plaintiffs should not be less than nine percent. Defendant, however, allocated to Plaintiffs the exact amount of credits specified in the agreements. Plaintiffs sued Defendant in federal court, alleging that Defendant had unlawfully seized the additional tax credits to which they were apparently entitled. Defendant moved for judgment on the pleadings, asserting, among other things, that Plaintiffs’ action was time-barred. The district court granted the motion, identifying three justifications supporting for the entry of judgment on the pleadings: waiver, untimeliness, and the absence of any cognizable property interest in the additional tax credits. The First Circuit affirmed on the basis that Plaintiffs’ action was brought outside the applicable limitations period, and equitable tolling did not apply.
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