Hawai’i Housing Authority v. Midkiff

Supreme Court of the United States

467 U.S. 229 (1984)

     Once the objective sought to be accomplished is shown to be within government authority, the right to realize that objective through eminent domain is clear.  Eminent domain is merely the mean to accomplish an end.

     The public use requirement (part of the Takings Clause) is coterminous with the power of the government itself.

     Deference is given to legislative determinations of what constitutes a valid public use.  A court should not substitute its judgment for a legislature’s, unless the proposed public use has no reasonable justification.  If the legislature (or government agency) determines there are substantial reasons to exercise eminent domain, courts must defer to that determination.

     One person’s private property may not be taken solely for the benefit of another private person, even if fair compensation is paid.  However, property may be taken by eminent domain and transferred to a private person if the taking is rationally related to a conceivable public purpose.  The transfer of land does not, by itself, invalidate the use of eminent domain.

Full Text of Hawai’i Housing Authority v. Midkiff

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