In its landmark decision in First English Evangelical Lutheran Church of Glendale v. County of Los Angeles,² the U.S. Supreme Court established that temporary regulatory takings must be compensated under the Fifth Amendment's Takings Clause.³ However, neither First English nor the Court's subsequent cases have comprehensively defined what constitutes a "temporary regulatory taking." Recently, the U.S. Court of Appeals for the Ninth Circuit held that development moratoria cannot result in compensable takings under First English, even when they deprive owners of all economically beneficial use of land for extended periods. The case, Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency,⁴ was decided in June 2000. The Ninth Circuit voted against en banc review in October,⁵ although a vehement dissent was filed.⁶ This Article reviews Tahoe-Sierra and concludes that the court's analysis is inconsistent with First English.