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Keywords

lawsuitplaintiffdefendantappealtrialcorporationeminent domainjudicial review
defendanttrialwillcorporationeminent domainappellee

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Poletown Neighborhood Council v. City of Detroit, 410 Mich. 616, 304 N.W.2d 455, 19 ERC 1972, 11 Envtl. L. Rep. 20,778

Facts

The Detroit Economic Development Corporation sought to acquire a large tract of land to be used by General Motors for an assembly plant. The neighborhood association and several residents filed a lawsuit to contest the project, arguing that the use of eminent domain for this purpose was unconstitutional. The trial court ruled in favor of the defendants, stating that the city did not abuse its discretion in determining the necessity of the condemnation. The plaintiffs appealed to the Supreme Court after the trial court's decision.

In the spring of 1980, General Motors Corporation informed the City of Detroit that it would close its Cadillac and Fisher Body plants located within the city in 1983. General Motors offered to build an assembly complex in the city, if a suitable site could be found.

Issue

Does the use of eminent domain in this case constitute a taking of private property for private use, thereby contravening the Michigan Constitution? Did the court err in ruling that cultural, social, and historical institutions were not protected by the Michigan Environmental Protection Act?

Does the use of eminent domain in this case constitute a taking of private property for private use and, therefore, contravene Const. 1963, Art. 10, s 2 ? Did the court below err in ruling that cultural, social and historical institutions were not protected by the Michigan Environmental Protection Act?

Rule

The power of eminent domain may be exercised for public use or purpose, and the determination of what constitutes a public purpose is primarily a legislative function, subject to judicial review only when it is manifestly arbitrary and incorrect.

The determination of what constitutes a public purpose is primarily a legislative function, subject to review by the courts when abused, and the determination of the legislative body of that matter should not be reversed except in instances where such determination is palpable and manifestly arbitrary and incorrect.

Analysis

The court found that the project served a public purpose as defined by the Economic Development Corporations Act, which aims to alleviate unemployment and promote economic development. The fact that the property would ultimately benefit a private corporation did not negate the public purpose of the project. The court emphasized that the legislature's determination of public purpose should be given deference unless it is clearly unreasonable.

The power of eminent domain is to be used in this instance primarily to accomplish the essential public purposes of alleviating unemployment and revitalizing the economic base of the community. The benefit to a private interest is merely incidental.

Conclusion

The Supreme Court affirmed the trial court's decision, concluding that the condemnation of property for the assembly plant served a legitimate public purpose and that the plaintiffs' claims regarding the Michigan Environmental Protection Act were without merit.

We conclude that these questions must be answered in the negative and affirm the trial court's decision.

Who won?

The Detroit Economic Development Corporation and General Motors prevailed in the case because the court upheld the use of eminent domain for a project deemed to serve a public purpose.

The defendants-appellees contend, on the other hand, that the controlling public purpose in taking this land is to create an industrial site which will be used to alleviate and prevent conditions of unemployment and fiscal distress.

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