Southeast Land Development Associates, LP v. District of Columbia

2005 WL 3211458 (2005)

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Southeast Land Development Associates, LP v. District of Columbia

United States District Court for the District of Columbia
2005 WL 3211458 (2005)

Facts

Hoping to entice a major-league baseball team to come to the District of Columbia (DC) (defendant), DC’s city council passed an act authorizing the acquisition of land, including via eminent domain, for a new stadium. The act’s first section reflected the council’s determination that the stadium would be a municipal use that would benefit DC’s citizens. Later sections of the act designated a preferred site for the stadium (primary site) and provided that a new site should be chosen if DC’s chief financial officer (CFO) estimated that DC’s land-acquisition costs for the primary site would exceed $165 million. The CFO ultimately estimated the land-acquisition costs to be $161.4 million. Southeast Land Development Associates, LP (Southeast) (plaintiff), a landowner at the primary site, sued DC, alleging that DC violated the Public Use Clause of the Fifth Amendment to the United States Constitution, which applies to takings through eminent domain, and violated Southeast’s substantive-due-process rights under the Fifth and Fourteenth Amendments. Specifically, Southeast claimed the city council determined the stadium would serve a public use only if the land-acquisition cost was less than $165 million but that the true land-acquisition cost would exceed $165 million, notwithstanding the CFO’s lower estimate, which the CFO allegedly derived using an incorrect formula. DC moved to dismiss the complaint.

Rule of Law

Issue

Holding and Reasoning (Roberts, J.)

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