Knick v. Township of Scott
Headline: Court overrules rule forcing property owners into state court, allows federal takings claims immediately when local governments take property without paying, affecting landowners challenging local regulations like cemetery rules.
Holding: The Court held that a property owner may sue in federal court under federal civil-rights law (Section 1983) as soon as a local government takes private property without just compensation, overruling the prior state-litigation requirement.
- Allows property owners to sue in federal court immediately after an uncompensated taking.
- Overrules requirement to pursue state inverse condemnation before federal suit.
- May shift many local land-use disputes into federal courts.
Summary
Background
A landowner in a small Pennsylvania township owned 90 acres that included a family graveyard. The township adopted an ordinance requiring cemeteries to be open to the public during daylight. After a code officer found grave markers, the owner sued in state court for a declaration and an injunction, but did not bring a state “inverse condemnation” suit to seek compensation. She then filed a federal claim saying the ordinance effected a taking without just compensation.
Reasoning
The Court addressed whether a property owner must first pursue a state compensation remedy before suing in federal court. Relying on earlier Fifth Amendment decisions, the majority held that a taking without payment violates the Constitution at the time of the taking. Therefore the owner can bring a federal suit under federal civil-rights law (Section 1983) as soon as the government takes property without just compensation. The Court overruled the prior rule that forced property owners to litigate first in state court.
Real world impact
Property owners may now bring federal takings claims immediately after an uncompensated taking. That does not mean governments cannot act: because post-taking compensation remedies exist, courts will usually deny injunctions and preserve government activity while money remedies are pursued. The Court also noted that a prior interaction between the earlier rule and preclusion law had blocked many federal suits, a problem this decision removes.
Dissents or concurrances
A concurring Justice agreed the text requires immediate enforcement. A dissent warned the decision departs from long-standing precedent and may push many state-law land-use questions into federal courts, raising federalism concerns.
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