Kelo v. City of New London, 545 U.S. 469 (2005)
Primary Holding
The Supreme Court held that the government's use of eminent domain to transfer land from one private owner to another for the purpose of economic development qualifies as a "public use" under the Takings Clause of the Fifth Amendment. This decision allows for a broader interpretation of public use to include economic benefits to the community.
In the Kelo v. City of New London case, the Supreme Court decided that the government can take private land and give it to another private owner if it will help improve the local economy, like creating jobs or increasing tax revenue. This matters because it expands the government's power to use land for development, which can lead to better community resources but also raises concerns about individual property rights. If someone is facing a situation where their property might be taken for a new development project, this case is relevant as it shows that the government has the legal backing to do so, as long as they provide fair compensation.
AI-generated plain-language summary to help you understand this case
Susette Kelo and other private property owners in the city of New London, Connecticut sued the city for an alleged abuse of its eminent domain power. The city government had condemned privately owned real estate within its boundaries and transferred it to the New London Development Corporation, a private entity, for a comprehensive redevelopment plan. The plaintiffs grounded their claim on an argument that the city's stated purpose of economic development was not a public use, as required to exercise the eminent domain power under the Fifth Amendment. However, a state law provided that economic development was a public use.
Whether the city’s proposed disposition of property through the use of eminent domain qualifies as a “public use” within the meaning of the Takings Clause of the Fifth Amendment to the Constitution.
The judgment is affirmed.
This decision was widely controversial and unpopular among the public, but it was not as startling as people may have believed. The Court's conflation of public use with public purpose had appeared in earlier decisions on eminent domain as well. Many observers found this outcome more unpalatable, however, since the city was essentially using its power to remove lower middle class property owners and seek wealthier residents, rather than trying to remedy social ills as in the older cases. As it turned out, the corporation never managed to get the funding for the redevelopment plan and left the property abandoned as an empty lot. None of the jobs or the other economic benefits materialized as Pfizer, the principal beneficiary of the project, changed its plans.
- Court
- Supreme Court
- Decision Date
- February 22, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.
Lingle v. Chevron U. S. A. Inc., 544 U.S. 528 (2005)
Consumer LostThe "substantially advances" formula established in Agins v. City of Tiburon is not an appropriate test for determining whether government regulation effects a taking under the Fifth Amendment.
City of Sherrill v. Oneida Indian Nation of N. Y., 544 U.S. 197 (2005)
Consumer LostThe Oneida Indian Nation cannot unilaterally revive its ancient sovereignty over lands purchased in an open market, as they have long relinquished governmental authority, and such a revival would disrupt the established governance of local municipalities.
Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg., 545 U.S. 308 (2005)
Consumer LostThe national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal question jurisdiction over a state action involving a disputed issue of federal title law, even in the absence of a federal cause of action.