Hawaii Housing Authority v. Midkiff
Hawaii Housing Authority v. Midkiff is a significant Supreme Court case that addresses the limits of eminent domain and the interpretation of "public use" in relation to property rights. The case arose from a Hawaii law aimed at reducing the influence of a few powerful landowners by allowing lessees of single-family homes to purchase the properties they occupied through eminent domain. Landowners contested the law, arguing that the government's actions did not constitute public use since the land was directly transferred to the former lessees. The Supreme Court, in a unanimous decision led by Justice Sandra Day O'Connor, ruled that a public use was established simply by the government’s role in the condemnation process, even if the property was transferred to a private individual immediately afterward. This ruling marked a shift in how the Court would interpret the public use doctrine, suggesting that the identity of the governmental body executing the action suffices to validate the appropriation of private property. The case highlights ongoing debates about property rights, government authority, and the balance between private ownership and public policy.
Hawaii Housing Authority v. Midkiff
Date: May 30, 1984
Citation: 467 U.S. 229
Issues: Takings clause; public use doctrine
Significance: The Supreme Court ruling in this Hawaii property case almost entirely eliminated public use as a limit on the government taking private property in condemnation proceedings.
A Hawaii law, designed to lessen the power of oligopoly landowners, allowed lessees of single family homes to invoke eminent domain and buy the property they leased. The landowners challenged the law, saying that the condemnation was not for public use because the government immediately turned the land over to the former lessee. Justice Sandra Day O’Connor wrote the unanimous opinion in this landmark case, quite clearly setting out that the Supreme Court would no longer use “public use” as a limit on future eminent domain actions. If a governmental body legislated the condemnation of private property, a public use occurred even if the property was immediately turned over to another private party. The public character of the government body making the condemnation was all that was required to give the action a public character. Justice Thurgood Marshall did not participate in this case.
