## Facts

- The City of Chicago decided to open and widen Rockwell Street between 18th and 19th Streets, requiring condemnation of private parcels and a railroad right-of-way.
- Chicago, Burlington & Quincy Railroad Company owned the affected right-of-way.
- In an Illinois condemnation proceeding, a jury awarded substantial compensation to individual landowners but awarded the railroad $1 for the effect on its right-of-way.
- The railroad argued the nominal award amounted to a taking of property without just compensation and therefore without due process under the Fourteenth Amendment.
- The City argued due process was satisfied because the railroad received notice and a full opportunity to be heard under state procedures.

## Issues

1. Whether the Supreme Court could review a state high court’s final condemnation judgment alleged to violate the Fourteenth Amendment.
2. Whether the Fourteenth Amendment’s Due Process Clause requires a state to provide just (fair) compensation when taking private property for public use.
3. Whether the $1 award, in the context of the state proceedings, amounted to a deprivation of property without due process of law.

## Decision

- The Court held that the Fourteenth Amendment’s Due Process Clause requires states to provide just (fair) compensation when they take private property for public use.
- The Court rejected the view that due process is satisfied solely by notice and an opportunity to be heard; substance, not form, must be considered.
- The Court affirmed the Illinois Supreme Court’s judgment and sustained the condemnation and the $1 award.
- The Court emphasized limits on federal reexamination of state jury determinations of compensation in this posture.
- Justice Brewer dissented; the Chief Justice did not participate.

## Legal Principles

- State takings without compensation made or secured to the owner violate the due process of law required by the Fourteenth Amendment.
- Due process analysis is not purely procedural; it requires attention to the substantive protection of property rights.
- A state may prescribe condemnation procedures, but those procedures must include provision for compensation.
- “Just compensation” is commonly expressed as a fair and full equivalent for what is taken.
- The Supreme Court may review state condemnation judgments when a federal constitutional claim is properly presented and the judgment operates against that federal right.

## Conclusion

The Court recognized that the Fourteenth Amendment obligates states to provide just compensation for takings, while nonetheless affirming the challenged condemnation judgment and nominal award based on the case’s posture and the constrained scope of federal review of state compensation findings.


Chi., Burlington & Quincy R.R. Co. v. City of Chicago, 166 U.S. 226 (1897)