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demonstrating that Fox would be selling the property. And she concluded by stating
“[p]lease clarify and resubmit your plans.” J.A. 311. The record contains no evidence of
Fox responding to Inspector Jackson.
In June 2018, the city prepared another notice of violation letter. Records do not
clarify whether the city mailed this letter, but it was posted to the house. In addition to
listing a series of code violations, the notice stated that the house “must be repaired or
demolished and removed within 30 days of the date of this notice.” J.A. 971. If Fox failed
to repair the house, the notice continued, the city would demolish it pursuant to the building
code. The notice also granted Fox an opportunity to appeal within the next fourteen days.
Fox neither appealed nor responded to the notice.
In December 2018, the city demolished the house at 615 Walker Avenue. Fox
learned of the demolition in late 2018. In early 2019, he spoke about it with Inspector
Jackson and other city officials.
B.
On December 13, 2021—almost three years after the demolition—Fox sued the city.
In an amended complaint, he alleged five causes of action: (1) a claim for due process
violations of the Fifth and Fourteenth Amendments under 42 U.S.C. § 1983; (2) a claim
for relief under the Servicemembers Civil Relief Act (“SCRA”), 50 U.S.C. §§ 3901–4043;
(3) a claim for violation of the Fourth Amendment’s protection against unreasonable
searches and seizures under 42 U.S.C. § 1983; (4) a Fifth Amendment takings claim for
just compensation under 42 U.S.C. § 1983; and (5) a state-law takings claim for just
compensation under an inverse condemnation theory, Va. Const. art. I, § 11; Va. Code
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