Facts
- Rose Mary Knick owned a 90-acre rural property in Scott Township, Pennsylvania.
- A portion of Knick’s land contained a small family graveyard.
- The Township enacted an ordinance requiring that all cemeteries within the Township be open and accessible to the public during daylight hours, effectively granting the public a right of access to any cemetery located on private land.
- The ordinance authorized Township officials to enter private property to determine whether a cemetery was present and to enforce the public-access requirement.
- A Township code-enforcement officer entered Knick’s property, identified what he believed were grave markers, and notified her that she was violating the ordinance by failing to make the cemetery accessible to the public during the day.
- Knick filed suit in Pennsylvania state court seeking declaratory and injunctive relief, alleging that the ordinance took her property without just compensation; she did not file a state inverse-condemnation action seeking compensation.
- After Knick filed in state court, the Township withdrew the violation notice and stayed enforcement against her; the state court declined to address the merits because Knick could not show irreparable harm required for equitable relief.
- Knick then sued in federal district court under 42 U.S.C. § 1983, alleging the ordinance violated the Fifth Amendment’s Takings Clause (and also raised a Fourth Amendment claim).
- The federal district court dismissed the takings claim as unripe under Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, which required property owners to seek and be denied compensation through state procedures before suing in federal court.
- The Third Circuit affirmed, and the Supreme Court granted certiorari to reconsider the Williamson County state-litigation requirement.
Issues
- Whether a property owner must first seek and be denied just compensation through state procedures before bringing a Fifth Amendment takings claim in federal court under 42 U.S.C. § 1983.
- Whether a takings claim is ripe in federal court at the time of an alleged taking without payment of just compensation.
Decision
- The Supreme Court held (5–4) that a property owner is not required to pursue and be denied compensation in state court before filing a federal takings claim under § 1983.
- The Court ruled that a Fifth Amendment violation occurs when the government takes property without paying just compensation; at that moment, the owner has a ripe federal claim.
- The Court overruled Williamson County’s state-litigation requirement, concluding it wrongly forced takings plaintiffs into state court first and often prevented later federal review because of preclusion rules.
- The Court vacated and remanded the Third Circuit’s judgment as to the Fifth Amendment claim, allowing Knick to proceed in federal court.
- The dissent argued that the Takings Clause is satisfied if the state provides a reasonable method to obtain compensation after the taking, and that no federal constitutional claim should exist until the state fails to provide compensation; it also objected to overruling precedent.
Legal Principles
- A government violates the Fifth Amendment’s Takings Clause when it takes private property for public use without providing just compensation.
- A federal takings claim under 42 U.S.C. § 1983 may be brought in federal court as soon as the alleged uncompensated taking occurs.
- A property owner is not required to first use state inverse-condemnation procedures (or other state compensation remedies) before suing in federal court under § 1983.
- Williamson County’s state-litigation ripeness requirement is no longer valid.
Conclusion
Knick v. Township of Scott holds that a property owner may file a § 1983 takings action in federal court immediately upon an alleged taking without just compensation, and it overrules Williamson County’s rule requiring plaintiffs to seek and be denied compensation in state court before a federal takings claim becomes ripe.