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Knick v. Township of Scott, Pennsylvania, 588 U.S. 180, 139 S.Ct. 2162, 204 L.Ed.2d 558, 19 Cal. Daily Op. Serv. 5784, 2019 Daily Journal D.A.R. 5491, 27 Fla. L. Weekly Fed. S 1020

Facts

Rose Mary Knick, the property owner, owned a 90-acre rural property in Scott Township, Pennsylvania, which included a small family graveyard. In December 2012, the Township passed an ordinance requiring that all cemeteries be kept open to the public during daylight hours. After being notified of a violation, Knick sought declaratory and injunctive relief in state court, claiming the ordinance constituted a taking of her property. The Township withdrew the violation notice, but the state court declined to rule on her request for relief, leading her to file a federal lawsuit under § 1983.

Rose Mary Knick, the property owner, owned a 90-acre rural property in Scott Township, Pennsylvania, which included a small family graveyard. In December 2012, the Township passed an ordinance requiring that all cemeteries be kept open to the public during daylight hours. After being notified of a violation, Knick sought declaratory and injunctive relief in state court, claiming the ordinance constituted a taking of her property.

Issue

Whether a property owner can bring a federal takings claim under § 1983 without first exhausting state law remedies for just compensation.

Whether a property owner can bring a federal takings claim under § 1983 without first exhausting state law remedies for just compensation.

Rule

A government violates the Takings Clause of the Fifth Amendment when it takes property without compensation, and a property owner may bring a Fifth Amendment claim under § 1983 at that time.

A government violates the Takings Clause when it takes property without compensation, and a property owner may bring a Fifth Amendment claim under § 1983 at that time.

Analysis

The Court analyzed the implications of the Williamson County decision, which had required property owners to seek compensation through state law before bringing a federal claim. The Court found that this requirement imposed an unjustifiable burden on takings plaintiffs and conflicted with established takings jurisprudence. It concluded that a property owner suffers a violation of the Takings Clause as soon as the government takes property without compensation, allowing for immediate federal claims under § 1983.

The Court analyzed the implications of the Williamson County decision, which had required property owners to seek compensation through state law before bringing a federal claim. The Court found that this requirement imposed an unjustifiable burden on takings plaintiffs and conflicted with established takings jurisprudence.

Conclusion

The Supreme Court overruled the state-litigation requirement established in Williamson County, affirming that property owners can bring federal takings claims as soon as their property is taken without compensation.

The Supreme Court overruled the state-litigation requirement established in Williamson County, affirming that property owners can bring federal takings claims as soon as their property is taken without compensation.

Who won?

The property owner, Rose Mary Knick, prevailed because the Supreme Court recognized her right to bring a federal takings claim without first exhausting state remedies.

The property owner, Rose Mary Knick, prevailed because the Supreme Court recognized her right to bring a federal takings claim without first exhausting state remedies.

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