Goldblatt v. Town of Hempstead, 369 U.S. 590 (1962)

Facts

  • Herbert W. Goldblatt owned a 38-acre tract in the Town of Hempstead, New York, used by Builders Sand and Gravel Corporation as a sand and gravel pit continuously since 1927.
  • Early excavation reached the water table, creating a water-filled crater that later became a roughly 20-acre lake averaging about 25 feet deep.
  • Over time, the surrounding area became densely developed, with more than 2,200 homes and four public schools within approximately 3,500 feet of the site.
  • In 1945, the Town adopted an ordinance regulating pit excavations through fencing and slope/berm requirements; Goldblatt complied, and his operation was treated as a lawful prior nonconforming use.
  • In 1958, the Town amended the ordinance to prohibit excavating below the water table and to require refilling of excavations already below the water table, while also tightening related safety requirements.
  • The amendment effectively prevented continuation of Goldblatt’s prior excavation method and led the Town to obtain an injunction enforcing the ordinance.

Issues

  1. Whether prohibiting excavation below the water table and requiring refilling of existing below-water-table excavations constituted an unconstitutional taking without due process under the Fourteenth Amendment.
  2. Whether the ordinance, despite ending a long-standing lawful use, was a reasonable, non-arbitrary exercise of municipal police power to protect public safety.

Decision

  • The Supreme Court affirmed the judgment upholding the ordinance and the injunction enforcing it.
  • The Court held that the challengers did not carry their burden to show the depth limitation and refilling requirement were so onerous and unreasonable as to amount to a taking without due process.
  • The Court accepted the ordinance as a safety measure reasonably related to the Town’s legitimate interest in protecting the public in light of the site’s size, depth, and proximity to homes and schools.
  • Police-power land-use regulations are presumed valid; the property owner bears the burden to prove a regulation is arbitrary or so unreasonable as to be confiscatory.
  • A regulation does not become unconstitutional solely because it deprives property of its most profitable use or prevents continuation of a preexisting, lawful use.
  • A restriction that substantially impairs a prior use may still be constitutional if reasonably related to a legitimate public purpose, such as public safety, and not shown to leave the property without any reasonable use.

Conclusion

The Court upheld Hempstead’s excavation restrictions as a reasonable safety regulation and concluded the owners failed to prove the ordinance was so extreme as to constitute a taking without due process under the Fourteenth Amendment.