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Zoning Bulletin August 10, 2011 I Volume 5 I No. 15 <br />The court concluded that this was not a case where postdeprivation rem- <br />edies could satisfy due process. Here, San Geronimo was not denied its per- <br />mits due to "random and unauthorized conduct by state officials." Instead, <br />the court concluded that this was a case of: "predictable overreaching by <br />government officials given broad discretion to choose the manner by which <br />property interests might be deprived." <br />Nevertheless, although San Geronimo had made out a valid procedural <br />due process claim, the court concluded that it had to be dismissed. The court <br />found the Defendants were entitled to qualified immunity because the state <br />law at the time did not put them "on clear notice that their failure to provide <br />predeprivation process violated [San Geronimo]'s constitutional rights." The <br />court found that statements in its prior decisions "could have easily led the <br />[D]efendants to believe that they were not required to provide a meaningful <br />predeprivation and hearing and that, under Parratt and Hudson, providing <br />postdeprivation remedies was all the process that was due." <br />See also: Hudson v. Palmer, 468 U.S. 517, 104 S. Ct. 3194, 82 L. Ed. 2d <br />393 (1984). <br />See also: Logan v. Zimmerman Brush Co., 455 U.S. 422, 102 S. Ct. 1148, <br />71 L. Ed. 2d 265, 28 Fair Empl. Prac. Cas. (BNA) 9, 28 Empl. Prac. Dec. <br />(CCH) P 32433 (1982). <br />See also: Zinermon v. Burch, 494 U.S. 113, 110 S. Ct. 975, 108 L. Ed. 2d <br />100 (1990). <br />Standing —Individual Owners of Corporations <br />That Operate Gas Stations in County <br />Challenged Permit Issued for New Gas Station <br />County says owners lack standing as individuals to bring <br />challenge <br />Citation: Gosain v. County Council of Prince George's County, 2011 WL <br />2462950 (Md. 2011) <br />MARYLAND (06/22/11)—This case addressed the issue of whether <br />stockholders and employees of corporations which owned businesses and <br />paid property taxes in the county had standing to challenge a county land <br />use determination. <br />The Background/Facts: Atapco Ritchie Interchange, Inc. ("Atapco") <br />sought to develop a portion of business park property it owned in Prince <br />George's County (the "County"). Among the proposed construction was a <br />gasoline service station with a convenience store. <br />© 2011 Thomson Reuters <br />