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Knick v. Township of Scott, Pennsylvania

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Supreme Court of the United States
Knick v. Township of Scott, Pennsylvania
Term: 2018
Important Dates
Argument: October 3, 2018 and January 16, 2019
Decided: June 21, 2019
Outcome
Vacated and remanded
Vote
5-4
Majority
John G. Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Brett Kavanaugh
Concurring
Clarence Thomas
Dissenting
Elena Kagan • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor


Knick v. Township of Scott, Pennsylvania is a case argued during the October 2018 term of the U.S. Supreme Court.

Argument in the case took place on October 3, 2018. The justices reheard the case on January 16, 2019. The court initially heard the case before Justice Brett Kavanaugh was confirmed. SCOTUSblog's Amy Howe said that the justices likely chose to rehear the case "to allow Kavanaugh to break a 4-4 tie." The case came on a writ of certiorari to the United States Court of Appeals for the 3rd Circuit. It was originally accepted to be heard during the October 2017 term but was deferred.[1]

The court vacated and remanded the Third Circuit's ruling, overturning the exahustion requirement established in Williamson County Regional Planning Commission v. Hamilton Bank.[2]

HIGHLIGHTS
  • The case: Mary Rose Knick challenged an ordinance passed by the Township of Scott in Pennsylvania, arguing that the ordinance violated the Takings Clause of the Fifth Amendment. Under an earlier Supreme Court case, Williamson County Regional Planning Commission v. Hamilton Bank, plaintiffs are required to exhaust all state court remedies before filing a takings claim in federal court. A federal district court, citing Williamson, dismissed Knick's lawsuit, ruling that Knick had failed to exhaust her state remedies. The Third Circuit affirmed. The U.S. Supreme Court accepted the appeal to consider whether it should overrule the exhaustion requirement under Williamson.
  • The issue: Should the Supreme Court overturn the exhaustion requirement established in Williamson County Regional Planning Commission v. Hamilton Bank?[3]
  • The outcome: The Court vacated and remanded the Third Circuit's ruling, overturning the exhaustion requirement established in Williamson.


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 21, 2019: U.S. Supreme Court vacated and remanded Third Circuit ruling
    • January 16, 2019: Second oral argument
    • October 3, 2018: Oral argument
    • March 5, 2018: U.S. Supreme Court agreed to hear case
    • October 31, 2017: Petition filed with U.S. Supreme Court
    • May 12, 2017: Third Circuit affirmed the district court's ruling, concluding that Williamson required Knick to exhaust state remedies before filing a federal lawsuit. Knick argued that she had exhausted state remedies by filing her state lawsuit, but the Third Circuit pointed to the existence of the state inverse-condemnation proceeding.

    Background

    This case focused on the takings clause of the Fifth Amendment of the United States Constitution. In certain circumstances, the government is permitted to take private property for public use. However, under the Fifth Amendment, the government may not take private property "without just compensation." When the government takes possession of private property for public use and the private owner raises a claim for just compensation under the Fifth Amendment, it is called a takings claim. Takings claims can include government seizure, regulation, or use of private property.[5]

    Under a Supreme Court case called Williamson County Regional Planning Commission v. Hamilton Bank, plaintiffs are required to exhaust all state court remedies before filing a takings claim in federal court. In this case, the Supreme Court granted the appeal specifically to consider whether it should overrule its earlier opinion in Williamson and eliminate that requirement.[4]

    Mary Rose Knick challenged an ordinance passed by the Township of Scott in Lackawanna County, Pennsylvania. The ordinance related to the regulation of cemeteries. "The ordinance authorizes officials to enter upon any property within the Township to determine the existence and location of any cemetery. The ordinance also compels property owners to hold their private cemeteries open to the public during daylight hours."[4]

    Knick owns property in the Township. In April 2013, the Township code enforcement officer entered Knick's property and concluded that some of the stones on her property were grave markers. The officer issued a notice of violation to Knick. Knick filed suit in Pennsylvania state court, seeking an injunction against the Township. The Township agreed to withdraw the violation and not enforce the ordinance against Knick. As a result of that agreement, the court did not issue a ruling. The Township later issued a new Notice of Violation to Knick. Knick filed a Petition for Contempt with the state court, which the state court denied. Although Knick filed a state lawsuit, she did not pursue an inverse-condemnation proceeding under Pennsylvania state law. An inverse-condemnation proceeding is a proceeding in which a property owner seeks compensation for a government taking.[4]

    In 2014, Knick filed a takings claim lawsuit in federal district court. The district court "dismissed Knick’s takings claim without prejudice and directed her to exhaust state remedies" under Williamson, specifically noting that Knick had not pursued an inverse-condemnation procedure under Pennsylvania law. Knick then appealed.[4]

    On appeal, the United States Court of Appeals for the 3rd Circuit affirmed the district court's ruling, concluding that Williamson required Knick to exhaust state remedies before filing a federal lawsuit. Knick argued that she had exhausted state remedies by filing her state lawsuit, but the Third Circuit pointed to the existence of the state inverse-condemnation proceeding.[4]

    Knick then appealed to the United States Supreme Court, and the court agreed to hear the case on March 5, 2018.

    Question presented

    Question presented:

    "Whether the Court should reconsider the portion of Williamson County Regional Planning Commission v. Hamilton Bank, 473 U.S. 172, 194-96 (1985), requiring property owners to exhaust state court remedies to ripen federal takings claims, as suggested by Justices of this Court?"[3]

    Outcome

    On June 21, 2019, the court vacated and remanded the ruling of the United States Court of Appeals for the 3rd Circuit. In a 5-4 opinion, the court overturned the requirement established in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City that a person claiming unlawful taking of their property by a state or local government must first seek all available options for redress in a state court before petitioning a federal court. It found that the requirement conflicted with the later ruling in San Remo Hotel, L.P. v. City and County of San Francisco that a state court's ruling in such cases precludes any federal judgment, creating a situation where a plaintiff had no opportunity to appeal a taking to the federal government until after it was too late for the federal government to act.[2] Chief Justice John G. Roberts delivered the opinion of the court.

    Opinion

    In his opinion, Chief Justice Roberts wrote:[2]

    “ We now conclude that the state-litigation requirement imposes an unjustifiable burden on takings plaintiffs, conflicts with the rest of our takings jurisprudence, and must be overruled. A property owner has an actionable Fifth Amendment takings claim when the government takes his property without paying for it. That does not mean that the government must provide compensation in advance of a taking or risk having its action invalidated: So long as the property owner has some way to obtain compensation after the fact, governments need not fear that courts will enjoin their activities. But it does mean that the property owner has suffered a violation of his Fifth Amendment rights when the government takes his property without just compensation, and therefore may bring his claim in federal court under §1983 at that time.[6] ”

    Concurring opinion

    Justice Thomas filed a concurring opinion.

    In his opinion, Thomas wrote:[2]

    “ Still, “[w]hen the government repudiates [its] duty” to pay just compensation, its actions “are not only unconstitutional” but may be “tortious as well.” Monterey v. Del Monte Dunes at Monterey, Ltd., 526 U. S. 687, 717 (1999) (plurality opinion). I do not understand the Court’s opinion to foreclose the application of ordinary remedial principles to takings claims and related common-law tort claims, such as trespass. I therefore join it in full.[6] ”

    Dissenting opinion

    Justice Kagan filed a dissenting opinion, joined by Justices Breyer, Sotomayor, and Ginsburg.

    In her dissent, Kagan wrote:[2]

    “ Today, the Court formally overrules Williamson County Regional Planning Comm’n v. Hamilton Bank of Johnson City, 473 U. S. 172 (1985). But its decision rejects far more than that single case. Williamson County was rooted in an understanding of the Fifth Amendment’s Takings Clause stretching back to the late 1800s. On that view, a government could take property so long as it provided a reliable mechanism to pay just compensation, even if the payment came after the fact. No longer. The majority today holds, in conflict with precedent after precedent, that a government violates the Constitution whenever it takes property without advance compensation—no matter how good its commitment to pay. That conclusion has no basis in the Takings Clause. Its consequence is to channel a mass of quintessentially local cases involving complex state-law issues into federal courts. And it transgresses all usual principles of stare decisis.[6] ”

    Text of the opinion

    Audio

    • Audio of January 16, 2019, oral argument:[7]

    • Audio of October 3, 2018, oral argument:[8]

    Transcript

    • Read the oral argument transcript from January 16, 2019 here.
    • Read the oral argument transcript from October 3, 2018 here.

    Outcome

    The case is pending adjudication before the U.S. Supreme Court.

    See also

    Footnotes

    1. ↑ SCOTUSblog, "Justices release January calendar," November 28, 2018
    2. ↑ 2.0 2.1 2.2 2.3 2.4 Supreme Court of the United States, "Knick v. Township of Scott, Pennsylvania, et. al.," June 21, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "Knick v. Township of Scott, Pennsylvania Question Presented," March 5, 2018
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 United States Court of Appeals for the 3rd Circuit, "Knick v. Township of Scott, Pennsylvania Opinion," June 19, 2017
    5. ↑ Legal Information Institute, "Takings," accessed March 29, 2018
    6. ↑ 6.0 6.1 6.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, Knick v. Township of Scott, Pennsylvania, argued January 16, 2019
    8. ↑ Supreme Court of the United States, Knick v. Township of Scott, Pennsylvania, argued October 3, 2018
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