Hawaii Housing Authority v. Midkiff
E579572
Hawaii Housing Authority v. Midkiff is a 1984 U.S. Supreme Court case that broadly interpreted the Fifth Amendment’s Public Use Clause to allow government use of eminent domain for economic and social policy goals, such as breaking up concentrated land ownership.
Statements (48)
| Predicate | Object |
|---|---|
| instanceOf |
Fifth Amendment case
ⓘ
U.S. Supreme Court case ⓘ constitutional law case ⓘ eminent domain case ⓘ |
| areaOfLaw |
eminent domain
ⓘ
property law ⓘ public use doctrine ⓘ |
| chiefJustice | Warren E. Burger NERFINISHED ⓘ |
| citation |
104 S. Ct. 2321
ⓘ
467 U.S. 229 ⓘ 81 L. Ed. 2d 186 ⓘ |
| concurringJustices | all participating Justices joined the majority opinion without separate concurrences ⓘ |
| constitutionalBasisForTakingsClauseApplication | incorporation of the Fifth Amendment against the states through the Fourteenth Amendment ⓘ |
| constitutionalProvisionInterpreted |
Fifth Amendment to the U.S. Constitution
NERFINISHED
ⓘ
Fourteenth Amendment Due Process Clause NERFINISHED ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1984-05-30 ⓘ |
| docketNumber | No. 83-141 ⓘ |
| factPattern | challenge to state program breaking up oligopolistic land ownership in Hawaii ⓘ |
| fullName | Hawaii Housing Authority, et al. v. Midkiff, et al. NERFINISHED ⓘ |
| geographicContext | land ownership concentration on the island of Oahu ⓘ |
| holding |
A taking is constitutional if it is rationally related to a conceivable public purpose.
ⓘ
Hawaii’s Land Reform Act did not violate the Public Use Clause. NERFINISHED ⓘ The Public Use Clause of the Fifth Amendment is coterminous with the scope of a sovereign’s police powers. NERFINISHED ⓘ The government may use eminent domain to transfer property from lessors to lessees to reduce concentrated land ownership. ⓘ |
| impact | expanded government authority to use eminent domain for economic and social policy goals ⓘ |
| jurisdiction | State of Hawaii NERFINISHED ⓘ |
| keyPrinciple |
a taking is not invalid merely because property is transferred to private beneficiaries
ⓘ
courts will not substitute their judgment for that of the legislature on what constitutes a public use if the use is rationally related to a conceivable public purpose ⓘ |
| landmarkStatus | leading case on the meaning of public use in U.S. takings law ⓘ |
| legalIssue |
constitutionality of state land redistribution program
ⓘ
scope of the Fifth Amendment Public Use Clause ⓘ |
| nonParticipatingJustice | Justice Thurgood Marshall did not take part in the decision NERFINISHED ⓘ |
| opinionAuthor | Justice Sandra Day O’Connor NERFINISHED ⓘ |
| oralArgumentDate | 1984-01-11 ⓘ |
| originatingJurisdiction | United States Court of Appeals for the Ninth Circuit NERFINISHED ⓘ |
| petitioner | Hawaii Housing Authority NERFINISHED ⓘ |
| precedentFor | broad deference to legislative judgments about public use ⓘ |
| publicUseInterpretation | public use includes public purpose such as remedying social and economic evils ⓘ |
| relatedCase |
Berman v. Parker
NERFINISHED
ⓘ
Kelo v. City of New London NERFINISHED ⓘ |
| remedySought | injunction against enforcement of Hawaii Land Reform Act condemnation provisions ⓘ |
| respondent | Frank E. Midkiff NERFINISHED ⓘ |
| result | judgment of the Ninth Circuit reversed ⓘ |
| standardOfReview | rational basis review for public use determinations ⓘ |
| stateLawInvolved | Hawaii Land Reform Act of 1967 NERFINISHED ⓘ |
| term | 1983 Term ⓘ |
| vote | 8-0 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.