The 7 Most Important Eminent Domain Cases

Eminent domain is the act of taking private property for public use. Enumerated in the Fifth Amendment of the U.S. Constitution, it gives states and the federal government the right to seize property for public use in exchange for just compensation (based on fair market value for a piece of land). The concept of eminent domain is connected to the functionality of the government, because the government needs to acquire property for infrastructure and services like public schools, public utilities, parks, and transit operations. Seven key court cases throughout the 19th and 20th centuries allowed the judiciary to define eminent domain. Most eminent domain challenges focus on whether the lands were taken for a purpose that qualifies as â€Å"public use† and whether the compensation provided was â€Å"just. Kohl v. United States Kohl v. United States (1875) was the first U.S. Supreme Court case to assess the federal government’s eminent domain powers. The government seized a portion of the petitioner’s lands without compensation for the purpose of building a post office, customs office, and other government facilities in Cincinnati, Ohio. The petitioners alleged that the court did not have jurisdiction, the government could not acquire the land without proper legislation, and that the government should accept an independent assessment of the lands value before compensating. In a decision delivered by Justice Strong, the court ruled in favor of the government. According to the majority opinion, eminent domain is a core and essential power afforded to the government through the Constitution. The government may develop legislation to further define eminent domain, but the legislation is not required to make use of the power. In the majority opinion, Justice Strong wrote: â€Å"If the right of eminent domain exists in the federal government, it is a right which may be exercised within the states, so far as is necessary to the enjoyment of the powers conferred upon it by the Constitution.† United States v. Gettysburg Electric Railroad Company In United States v. Gettysburg Electric Railroad Company (1896), Congress used eminent domain to condemn the Gettysburg Battlefield in Pennsylvania. The Gettysburg Railroad Company, who owned land in the condemned area, sued the government, alleging that the condemnation violated their Fifth Amendment right. The majority ruled that as long as the railroad company was paid fair market value for the land, the condemnation was lawful. In terms of public use, Justice Peckham, on behalf of the majority wrote, â€Å"No narrow view of the character of this proposed use should be taken. Its national character and importance, we think, are plain.† Furthermore, the court held that the amount of land needed in any eminent domain seizure is for the legislature to determine, not the court. Chicago, Burlington Quincy Railroad Co. v. City of Chicago Chicago, Burlington Quincy Railroad Co. v. City of Chicago (1897) incorporated the Fifth Amendment takings clause using the Fourteenth Amendment. Prior to this case, states had used eminent domain powers unregulated by the Fifth Amendment. This means that states may have seized property for public use without just compensation. In the 1890s, the city of Chicago aimed to connect a stretch of road, even though it meant cutting through private property. The city condemned the land through a court petition and paid just compensation to the property owners. Quincy Railroad Corporation owned part of the condemned land and was awarded $1 for the taking, prompting the railroad to appeal the judgment. In a 7-1 decision delivered by Justice Harlan, the court ruled that the state could take land under eminent domain if the original owners were awarded just compensation. The taking of the Railroad Company’s land had not deprived the company of its use. The street only bisected the railroad tracts and did not cause the tracts to be removed. Therefore, $1 was just compensation. Berman v. Parker In 1945, Congress established the District of Columbia Redevelopment Land Agency to authorize the seizure of â€Å"blighted† housing districts for rebuilding. Berman owned a department store in the area slated for redevelopment and did not want his property to be seized along with the â€Å"blighted† area. In Berman v. Parker (1954), Berman sued on the basis that the District of Columbia Redevelopment Act  and its seizure of his land violated his right to due process. In a unanimous decision delivered by Justice Douglas, the court found that the seizure of Berman’s property was not a violation of his Fifth Amendment right. The Fifth Amendment does not specify what the land must be used for outside of â€Å"public use. Congress has the power to decide what this use might be and the goal of turning the land into housing, specifically low-income housing, fit the general definition of the takings clause. The majority opinion by Justice Douglas read: â€Å"Once the question of the public purpose has been decided, the amount and character of land to be taken for the project and the need for a particular tract to complete the integrated plan rests in the discretion of the legislative branch.† Penn Central Transportation v. New York City Penn Central Transportation v. New York City (1978) asked the court to decide whether a Landmark Preservation Law, which restricted Penn Station from building a 50-story building above it, was constitutional. Penn Station argued that preventing the construction of the building amounted to an illegal taking of the airspace by the City of New York, violating the Fifth Amendment. The court ruled in a 6-3 decision that the Landmarks Law was not a violation of the Fifth Amendment because restricting the construction of a 50-story building did not constitute a taking of the airspace. The Landmarks Law was more closely related to a zoning ordinance than eminent domain, and New York had a right to restrict construction in the public interest of protecting the â€Å"general welfare† of the surrounding area. Penn Central Transportation could not prove that New York had meaningfully â€Å"taken† the property simply because they had lowered the economic capacity and interfered with the property rights. Hawaii Housing Authority v. Midkiff Hawaii’s Land Reform Act of 1967 sought to tackle the issue of unequal land ownership on the island. Seventy-two private landowners possessed 47% of the land. Hawaii Housing Authority v. Midkiff (1984) asked the court to determine whether the state of Hawaii could enact a law that would use eminent domain to take lands from lessors (property owners) and redistribute them to lessees (property renters). In a 7-1 decision, the court ruled that the Land Reform Act was constitutional. Hawaii sought to use eminent domain to prevent a concentration of private ownership, a purpose generally associated with good democratic governance. Additionally, the state legislature has just as much power to make this determination as Congress. The fact that the property was transferred from one private party to another did not defeat the public nature of the exchange. Kelo v. City of New London In Kelo v. City of New London (2005), the plaintiff, Kelo, sued the city of New London, Connecticut for seizing her property under eminent domain and transferring it to New London Development Corporation. Susette Kelo and others in the area had refused to sell their private property, so the city condemned it to force them to accept compensation. Kelo alleged that the seizure of her property was a violation of the â€Å"public use† element of the Fifth Amendment takings clause because the land would be used for economic development, which is not solely public. Kelo’s property was not â€Å"blighted,† and it would be transferred to a private firm for economic development. In a 5-4 decision delivered by Justice Stevens, the court upheld aspects of its ruling in Berman v. Parker and Hawaii Housing Authority v. Midkiff. The court ruled that redistributing the land was part of a detailed economic plan that included public use. Even though the transfer of land was from one private party to another, the goal of that transfer–economic development–served a definitive public purpose. In this case, the court further defined â€Å"public use† by explaining that it was not confined to literal usage by the public. Rather, this term could also describe public benefit or general welfare. Sources Kohl v. United States, 91 U.S. 367 (1875).Kelo v. New London, 545 U.S. 469 (2005).United States v. Gettysburg Elec. Ry. Co., 160 U.S. 668 (1896).Penn Central Transportation Co. v. New York City, 438 U.S. 104 (1978).Hawaii Housing Auth. v. Midkiff, 467 U.S. 229 (1984).Berman v. Parker, 348 U.S. 26 (1954).Chicago, B. Q. R. Co. v. Chicago, 166 U.S. 226 (1897).Somin, Ilya. â€Å"The Story behind Kelo v. City of New London.†Ã‚  The Washington Post, 29 May 2015, www.washingtonpost.com/news/volokh-conspiracy/wp/2015/05/29/the-story-behind-the-kelo-case-how-an-obscure-takings-case-came-to-shock-the-conscience-of-the-nation/?utm_term.c6ecd7fb2fce.â€Å"History of the Federal Use of Eminent Domain.†Ã‚  The United States Department of Justice, 15 May 2015, www.justice.gov/enrd/history-federal-use-eminent-domain.â€Å"Constitutional Law. Federal Power of Eminent Domain.†Ã‚  The University of Chicago Law Review, vol. 7, no. 1, 1939, pp. 166–169.  JSTOR, JSTOR, www.j stor.org/stable/1596535.â€Å"Annotation 14 - Fifth Amendment.†Ã‚  Findlaw, constitution.findlaw.com/amendment5/annotation14.html#f170.

A Study On The Classroom - 903 Words

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Substance Abuse Counselor Career Essay - 919 Words

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Business Research for Journal of Sociology - myassignmenthelp

Question: Discuss about theBusiness Research for Journal of Sociology. Answer: Reflective report: The questionnaire method that has been used by the students in the case is very appropriate as per the requirements of the research and the type of data collected (Wright, 2005). Questionnaire is the type of survey method that is circulated amongst the sample so as to be filled by them. The questionnaire that has been used has mixed questions that are open ended as well as close ended. Thus, it provides all types of information to the student and the respondent also can convey their opinions freely by the open ended questions (Sieber, 1973). Some of the disadvantages and advantages of this method are: Advantages of questionnaire: Large information: it has been analysed that questionnaire I the method that allow the researchers to have large amount if information in less time from the large number of respondents. Easy: It is the meth that is easy to circulate as well as it is easy to fill by the respondents. Respondents find it easy to fill the questionnaire as they can write or fill their opinions very freely (Burns and Bush, 2006). Quick results: it is also one of the major advantage of questionnaire that it can give quick results and the analysis of the results it also very easy because the similar type of questions are filled by the respondents thus it is easy to quantify as well. Disadvantages of questionnaire: Less validity: It has been analysed that t depends on the mood of the respondent that how they fill the questionnaire. It can be wrong. Understanding: It has also been identified that the questions that has been written I the questionnaire may not be understood by the respondents and they may fill it without understanding (Fricker and Schonlau, 2002). Different perception different people have their different perception regarding the same question and thus the accuracy of the results may vary because of the difference in the perception of the respondents. False information: when the questionnaire is circulated online, it is not necessary that it is filled by the right candidate who was being targeted for the questionnaire and thus it affect the accuracy go the result. As far as the whole research is considered, it has been analysed that procedure is very successful. There are some shortcomings of the process used but the questions that have been involved in the questionnaire were very easy to understand by the respondents (Malhotra, Birks, Palmer and Koenig-Lewis, 2003). It has been analysed at the time of research that the close ended questions were easily filled by the respondents but the questions that are open ended were not filled so easily by the respondents. This is because they have to analyse their one perception at that points and they do not have any options to mark (Kaplowitz, Hadlock and Levine, 2004). This makes them to put some efforts in thinking about the subject related to the question. Some of the questions were very easy but the question that was related to the experience of their journey got negative answers from most of the respondents. This suggest that people remembers the bad experiences and the not good one. It has been i dentified that the question that are involves the questionnaire covers almost all the information required for the research and respondents have filled the questionnaire in less than 20 minutes which suggests they did not find it difficult to fill that. Although the whole administration procedure that has been used in the research was very well executed but there is still some of the scope of improving the practices and the activities that are conducted at the time of conducting the survey. The major area where the improvement can be made is the method of circulating the questionnaire (Kiesler and Sproull, 1986). It is recommended that the questionnaire should be circulated through the offline means and the researchers should sit with the respondents at the time when the questionnaire is being filled by them. This is because this may develop the strength or the accuracy of the answers filled. There should be some more open ended questions in the questionnaire because it may provide more chance to the respondents to give their own opinions. More of the close ended questions restrict the choices of answers to them. If the changes need to be made in the questionnaire, it is required to make it before circulating it to the large audience (Moorman, Zaltman and Deshpande, 1992). This is because it may affect the accuracy of the results and changing made after circulating may confuse the larger audience to fill it. It may also results in lack of interest of the respondents to fill the questionnaire. It has been analysed that the researcher should circulate the questionnaire to the small audience at first. After analysing their answers, the researchers should make the changes as per the requirements. This enhances the quality of the questionnaire and the survey as well. This is because the changes are made at early stage of the research and more efforts are not required by the researchers. When the researchers have to make the changes after circulating the questionnaire to the larger respondents, it becomes very difficult to alter the questions because the respondents may lose interest in filling the questionnaire and thus it will affect the full research. There are several lessons that I have learned after conducting this survey. This first lesson that I have learnt is about assuming the behaviour of the people. This is because when the survey needs the done, it is required to make the questionnaire by putting yourself at the place of the respondents. This is the best way to design the questionnaire. Have also learned to sort the things and follow the actions step by step. This I because following the procedure is very important in conducting the research d designing the questionnaire. It is the first requirement of the student to jot down the information points that are required to be collected so that the questions can be made accordingly. Communication is another skill that I have learnt. I have realised that my communication skills have been polished after thus survey because I have met with many people and interacted with them regarding their experiences. It was really a great experience to interact with the strangers and hearing their part on the subject. It has been analysed by this survey that different people have different perception regarding the same things. This is because the people who hate a service of a jet company are loved by some other passenger. This suggests nothing is correct and wring. It is thinking of the people that can make things right and wrong. One of the other lessons that I have learnt from this research is hard work. I have realised that conducting a survey is not an easy task. It is required by the researchers to understand the part of the respondents, look for the particular respondents that can give proper answers and quantifying those answers to make a conclusion out of it. All these activities that are being conducted by the researchers are not that easy. Any variation or alteration in the process at any of the point may ruin the whole research thus it is recommend to the researchers that they should conduct the research with small sample first and then should conduct it at the large level. References: Burns, A.C. and Bush, R.F., 2006. Marketing research.Globalization,1(7). Fricker, R.D. and Schonlau, M., 2002. Advantages and disadvantages of Internet research surveys: Evidence from the literature.Field methods,14(4), pp.347-367. Kaplowitz, M.D., Hadlock, T.D. and Levine, R., 2004. A comparison of web and mail survey response rates.Public opinion quarterly,68(1), pp.94-101. Kiesler, S. and Sproull, L.S., 1986. Response effects in the electronic survey.Public Opinion Quarterly,50(3), pp.402-413. Malhotra, N.K., Birks, D.F., Palmer, A. and Koenig-Lewis, N., 2003. Market research: an applied approach.Journal of marketing management,27, pp.1208-1213. Moorman, C., Zaltman, G. and Deshpande, R., 1992. Relationships between providers and users of market research: The dynamics of trust within and between organizations.Journal of marketing research,29(3), p.314. Sieber, S.D., 1973. The integration of fieldwork and survey methods.American journal of sociology,78(6), pp.1335-1359. Wright, K.B., 2005. Researching Internet?based populations: Advantages and disadvantages of online survey research, online questionnaire authoring software packages, and web survey services.Journal of Computer?Mediated Communication,10(3), pp.00-00.