## Facts

- The District enacted the Ballpark Omnibus Financing and Revenue Act of 2004 authorizing acquisition of a designated “primary” site and construction of a publicly funded Major League Baseball stadium, and declaring the project a municipal use benefiting District residents.
- The statute required the District’s Chief Financial Officer (CFO) to estimate land-acquisition costs; if the estimate exceeded $165 million, the District was to select an alternate site.
- The CFO estimated land-acquisition costs at approximately $161.4 million, and the District proceeded with the primary site, which included property owned by Southeast Land Development Associates, L.P.
- Southeast alleged the CFO’s estimate was understated due to an incorrect or incomplete methodology and that actual land-acquisition costs would exceed $165 million.
- Southeast sued in federal district court seeking declaratory and injunctive relief to prevent condemnation, asserting violations of the Fifth Amendment’s Public Use Clause and substantive due process.
- While the federal case was pending, the District initiated a “quick-take” condemnation proceeding in D.C. Superior Court, filed a declaration of taking, and deposited estimated just compensation, transferring title subject to litigation of objections and compensation.
- The District moved to dismiss the federal complaint.

## Issues

1. Whether condemnation for the stadium violated the Fifth Amendment Public Use Clause based on allegations that land-acquisition costs effectively exceeded a statutory $165 million threshold.
2. Whether reliance on the CFO’s allegedly flawed cost estimate constituted arbitrary or conscience-shocking action violating substantive due process.
3. Whether injunctive or declaratory relief in federal court was unavailable because the condemnation proceeding provided a plain, adequate, and complete remedy at law.

## Decision

- The court granted the District’s motion to dismiss and dismissed the complaint.
- The court held the stadium project satisfied the Public Use Clause and declined to invalidate the taking based on disputes over cost estimation or alleged statutory misapplication.
- The court held the alleged miscalculation or budgeting error did not rise to the level of a substantive due process violation.
- The court held equitable relief was inappropriate because Southeast could raise objections and seek just compensation in the pending condemnation action, providing an adequate remedy at law.

## Legal Principles

- Legislative determinations that a taking serves a public use receive substantial judicial deference; courts generally assess the public purpose of the project rather than the quality of cost estimates or budgeting decisions.
- A statutory cost cap or site-selection trigger does not, without more, convert a concededly public project into a non-public use for Fifth Amendment purposes.
- Substantive due process in the land-use/eminent-domain setting requires egregious governmental conduct; alleged errors in methodology, statutory interpretation, or administrative judgment ordinarily do not meet that threshold.
- Federal equitable intervention to halt a taking is generally unavailable where condemnation procedures provide a forum to assert defenses and the Constitution guarantees just compensation, supplying a plain and adequate remedy at law.

## Conclusion

The court dismissed a property owner’s attempt to block stadium-related condemnation on public-use and substantive due process grounds, concluding that the project remained a valid public use, the alleged cost-estimation errors were not constitutionally arbitrary, and the owner’s remedies lay in the local condemnation proceeding and just-compensation process.


Southeast Land Dev. Assocs., L.P. v. District of Columbia, No. 05-1413 (RJR), 2005 WL 3211458 (D.D.C. Nov. 30, 2005)