Cases Study
Chicago, Burlington, and Quincy R.R. v. City of Chicago, 166 U.S. 226 (1897)
A. Analysis/Significance
In this case, the U.S. Supreme Court sought to determine whether the decision by the Circuit Court to condemn, as well as compensate the plaintiff, violated the Due Process Clause of the Fourteenth Amendment. Of the eight justices, seven affirmed the ruling by the lower Court. The holding is of great importance because this is the first case in the American judicial system’s history to have integrated the Takings Clause of the Bills of Rights into a court ruling against a state.
B. Reasoning/Rationale
In its reasoning, the Court was guided by the rule that the clause’s primary role is to forbid any given states from depriving private owners of their legally owned property without abiding by the Due Process. The Court argued that the approval of the fifth article in April 1982 allowed the appropriate use of private property, including a right-of-way, while at the same time, providing that there will be no compensation for railroads. On the other hand, Justice Brewer dissented the ruling, arguing that the decision to compensate Quincy Railroad a mere $1 was unfair and nominal. The concurring opinion followed that the Court’s decision paved the way for even better interpretation of state statutes regarding private property and rules or laws governing streets, alleys, highways, and streets.
United States v. Carolene Products Co., 304 U.S. 144 (1938)
A. Analysis/Significance
Having ruled in favor of the 1923 Congressional Filled Milk Ac, the Court’s decision has so far created the doctrine of the preferred freedom. Moreover, as a result of this case, there is increased recognition among dietitians, the public, and scientists of the importance attached to the scrutiny of whole milk and other foods to prevent diseases and improve public health.
B. Reasoning/Rationale
Guided by the issue of whether the Act violated the 5th Amendment’s Due Clause, the Supreme Court held the lower Court’s ruling in a 5-1 vote. Equally important, the Court followed a clear rule that provides that shipping filled milk remains a permissible commercial regulation that is subjected to the 5th Amendment restrictions. Drawing from the Hebe Co. v. Shaw case, the Court reasoned that the newly introduced Act was consistent with the 5th Amendment’s clause on the regulation of interstate commerce. In concurrence, Justice Black contended that the Act of desiccating, condensing, drying, evaporating, and powdering or concentrating skimmed milk and milk cream constitute the prohibited filled milk category.
Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992)
A. Analysis/Significance
In the search to determine whether Lucas, the petitioner, was entitled to receive fair compensation as provided in the Takings Clause of the 5th Amendment, six of the eight sitting judges reversed the ruling by the lower Court. Most importantly, the case outcome led to the establishment of the modern-day and widely adopted total takings test.
B. Reasoning/Rationale
Before reaching the above landmark ruling, the Court reasoned by following the rule that any given regulations become a taking when they go a long way in stripping property of its economic value, especially when the current or existing state law does not consider the use of the property a nuisance. For this reason, the Court ordered a total taking analysis based on three things. First, determining the extent of harm to adjacent private properties, public lands, and posed by the proposed development or activity. Second, the social value and suitability of the claimant’s proposed activities. Third, the relative ease involved in avoiding the alleged harm. This reasoning was meant to establish whether the use of the property would be a nuisance.
In contrast, the dissenting judges opposed the reasoning by arguing that it was erroneous for the Court to declare that the property in question lost all its economic value. At the same time, they were convinced that the takings jurisprudence followed an ad-hock factual inquiry.
Kelo v. City of New London, 125 S. Ct. 2655 (2005)
A. Analysis/Significance
In response to the issue at hand, which revolved around the possibility of New London City violating the Takings Clause following its seizure and sale of private property for public use, the Court held the lower Court’s ruling. The justices supported their decision by arguing that private development represented or qualified as a provision of the Takings Clause on public use, which means New London did not breach the 5th Amendment’s Takings Clause. The importance of the case’s outcome created a new rule on the criteria for seizing private property, implying that the society needs throughout the country vary from jurisprudence to another.
B. Reasoning/Rationale
In their judgment, the Justices followed a given rationale governed by the rule that, under the Takings Clause, the promotion of economic development remains a widely accepted traditional function of any given state government. The Court argued that the seizure by New London did not involve the use of the private property for personal gains, but rather public economic development, which the Takings Clause supports. The concurring judges did not find any breach of the clause as the properties in question were used for the public good. On the other hand, the dissenting justices did not object to the ultimate purpose the takings could serve. Still, they insisted that the defendant failed to demonstrate how each economic development goal would be realized, making the takings unconstitutional.
References
Chicago, Burlington, and Quincy R.R. v. City of Chicago, 166 U.S. 226 (1897).
Kelo v. City of New London, 125 S. Ct. 2655 (2005)
Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992)
United States v. Carolene Products Co., 304 U.S. 144 (1938)
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