Introduction

Knick v. Township of Scott, 139 S. Ct. 2162 (2019), is a landmark decision by the United States Supreme Court that fundamentally reshaped the landscape of federal takings claims under the Fifth Amendment's Takings Clause. This case addressed whether property owners must exhaust state inverse condemnation procedures before bringing a federal claim for a taking, a requirement established by the precedent set in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985). Rose Mary Knick, the petitioner, challenged a township ordinance that required cemeteries to remain open to the public during daylight hours, which she argued effectively took her property without just compensation.

Summary of the Judgment

The Supreme Court, in an opinion delivered by Chief Justice Roberts, overruled the longstanding Williamson County decision. The Court held that the state-litigation requirement—mandating that property owners must first seek compensation through state inverse condemnation procedures before bringing a federal §1983 takings claim—is unconstitutional. The Court concluded that this requirement imposes an unjustifiable burden on takings plaintiffs and conflicts with the broader jurisprudence interpreting the Takings Clause. Consequently, property owners may now bring claims in federal court immediately upon the taking of their property without the need to exhaust state remedies first.

Analysis

Precedents Cited

The judgment extensively reviewed and critiqued prior cases, notably:

• Williamson County Regional Planning Comm'n v. Hamilton Bank of Johnson City (1985): Established the state-litigation requirement.
• San Remo Hotel, L.P. v. City and County of San Francisco (2005): Highlighted the preclusive effect of state court rulings on federal claims.
• Cherokee Nation v. Southern Kansas R. Co. (1890) and JACOBS v. UNITED STATES (1933): Affirmed that compensation rights arise at the time of the taking.
• First English Evangelical Lutheran Church of Glendale v. County of Los Angeles (1987): Confirmed that compensation rights are immediate and irrevocable upon taking.

The Court criticized Williamson County for misunderstanding the Fifth Amendment and not aligning with these precedents, which recognize an immediate right to compensation upon a taking.

Legal Reasoning

The Court's reasoning centered on the inherent rights granted by the Takings Clause, emphasizing that a violation occurs the moment property is taken without just compensation, irrespective of state proceedings. The ruling dismantles the "Catch-22" created by Williamson County, where federal claims were effectively rendered inert due to their dependence on failed state litigation. By overruled this requirement, the Court restored the property owner's ability to seek federal relief immediately, aligning takings claims with other constitutional rights that do not necessitate exhausting state remedies first.

Impact

The decision has profound implications:

• Federal Jurisdiction: Empowers property owners to pursue takings claims directly in federal court, streamlining the litigation process.
• Legal Consistency: Harmonizes takings jurisprudence with the broader Bill of Rights, ensuring uniform access to federal remedies.
• Government Regulation: While it facilitates property owners' rights, the decision reassures governments that compensation mechanisms still prevail, preventing automatic injunctions against regulations.
• Future Litigation: Anticipates increased federal takings claims, potentially overwhelming federal courts with cases previously confined to state jurisdictions.

Complex Concepts Simplified

Takings Clause

The Takings Clause of the Fifth Amendment prohibits the government from taking private property for public use without providing just compensation to the owner. This fundamental principle ensures that property rights are respected and that owners are fairly compensated if their property is expropriated.

Inverse Condemnation

Inverse condemnation refers to a legal action initiated by a property owner against the government, claiming that their property has been taken or significantly damaged by regulatory actions without compensation, thereby violating the Takings Clause.

Section 1983

42 U.S.C. § 1983 is a federal statute that allows individuals to sue state and local government officials for civil rights violations. In the context of takings, it enables property owners to seek federal redress for violations of their constitutional rights.

State-Litigation Requirement

Previously established by Williamson County, this requirement mandated that property owners exhaust all available state remedies for compensation before they could bring a federal claim under §1983. This created a barrier to accessing federal courts for takings claims.