Question juridique clé
Whether the 1995 non-zoning of parcel 1643 amounted to compensable expropriation
Solution extraite
No compensation was due because the parcel was not in the built-up area, could not reasonably be regarded as securely serviceable by the critical date, and the owners only had a speculative expectation of zoning.
Motifs extraits
Non-zoning is exceptional only for land that is overbuildable or already sufficiently serviced, combined with significant actual expenditures or particularly strong reliance interests. Here, the expenditures were mainly planning and project costs, and the owners bore the planning risk themselves.