Knick v. Township of Scott, Pennsylvania

139 S. Ct. 2162, 204 L. Ed. 2d 558, 588 U.S. __ (2019)

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Knick v. Township of Scott, Pennsylvania

United States Supreme Court
139 S. Ct. 2162, 204 L. Ed. 2d 558, 588 U.S. __ (2019)

Facts

Rose Mary Knick (plaintiff) owned 90 acres of land in Scott, Pennsylvania (the town) (defendant). A portion of Knick’s land was used as a small family graveyard. After the town passed an ordinance that required all cemeteries to be kept open and accessible to the public, Knick sought declaratory and injunctive relief, alleging that the ordinance effected a taking of her property. However, Knick did not bring an inverse-condemnation action seeking compensation under state law. The state court declined to rule on Knick’s request for equitable relief. Knick then filed an action in federal court under 42 U.S.C. § 1983, alleging that the ordinance violated the Takings Clause of the Fifth Amendment. The district court dismissed Knick’s claims because Knick had not sought compensation in state court before bringing a federal takings claim. The United States Court of Appeals for the Third Circuit affirmed. The lower courts relied on a United States Supreme Court case that held that a property owner whose property has been taken by a local government must be denied just compensation by a state court under state law before the property owner can pursue a federal takings claim in federal court. The United States Supreme Court granted certiorari in Knick’s case to reconsider that prior holding.

Rule of Law

Issue

Holding and Reasoning (Roberts, C.J.)

Dissent (Kagan, J.)

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