Kelo v. City of New London

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Kelo v. New London
Supreme Court of the United States
Argued February 22, 2005 Decided June 23, 2005
Full case name: Susette Kelo, et al. v. City of New London, Connecticut, et al. Docket #: 04-108 Citations: 545 U.S. 469; 125 S. Ct. 2655; 162 L. Ed. 2d 439; 2005 U.S. LEXIS 5011; 60 ERC (BNA) 1769; 18 Fla. L. Weekly Fed. S 437 Prior history: Judgment defendants as regarding certain plaintiffs, judgment for remaining plaintiffs, Kelo v. City of New London, 2002 Conn. Super. LEXIS 789 (Conn. Super. Ct. Mar. 13, 2002); affirmed and reversed in part, remanded, 843 A.2d 500 (Conn. 2004); cert. granted, 542 U.S. 965 (2004) Procedural history: Writ of Certiorari to the Supreme Court of Connecticut Subsequent history: Rehearing denied, 126 S. Ct. 24 (2005) Argument: Link to Oral Argument
Holding
The governmental taking of property from one private owner to give to another in furtherance of economic development constitutes a permissible "public use" under the Fifth Amendment. Supreme Court of Connecticut affirmed.
Court membership
Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer
Case opinions
Majority by: Stevens Joined by: Kennedy, Souter, Ginsburg, Breyer Concurrence by: Kennedy Dissent by: O'Connor Joined by: Rehnquist, Scalia, Thomas Dissent by: Thomas
Laws applied
U.S. Const. amend. V

Kelo v. City of New London, 545 U.S. 469 (2005)^[1], was a case decided by the Supreme Court of the United States involving the use of eminent domain to transfer land from one private owner to another to further economic development. The case arose from the condemnation by New London, Connecticut, of privately owned real property so that it could be used as part of a comprehensive redevelopment plan. The Court held in a 5-4 decision that the general benefits a community enjoyed from economic growth qualified such redevelopment plans as a permissible "public use" under the Takings Clause of the Fifth Amendment.

The decision was widely criticized by American politicians and the general public. Many members of the general public viewed the outcome as a gross violation of property rights and as a misinterpretation of the Fifth Amendment, the consequence of which would be to benefit large corporations at the expense of individual homeowners and local communities. Some in the legal profession construe the public's outrage as being directed not at the interpretation of legal principles involved in the case, but at the broad moral principles of the general outcome.^[2]

[edit] History

The case was appealed from a decision in favor of the city of New London by the Supreme Court of Connecticut, which found that the use of eminent domain for economic development (the central focus of the case) did not violate the public use clauses of the state and federal constitutions. The court found that if an economic project creates new jobs, increases tax and other city revenues, and revitalizes a depressed (even if not blighted) urban area, it qualifies as a public use. The court also found that government delegation of eminent domain power to a private entity was also constitutional as long as the private entity served as the legally authorized agent of the government.

The United States Supreme Court granted certiorari to consider questions first raised in Berman v. Parker, 348 U.S. 26 (1954) and later in Hawaii Housing Authority v. Midkiff, 467 U.S. 229 (1984) [1]. Namely, does a "public purpose" constitute a "public use" for purposes of the Fifth Amendment's Taking Clause, "nor shall private property be taken for public use, without just compensation"? Specifically, does the Fifth Amendment, applicable to the states through the Due Process Clause of the Fourteenth Amendment (see main article: Incorporation of the Bill of Rights), protect landowners from the use of eminent domain for economic development, rather than, as in Berman, for the elimination of slums and blight?

[edit] The case

[edit] The development plan

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The city of New London, Connecticut, had by the early 2000s fallen on hard economic times. The city's tax base and population were continually decreasing, and city leaders were growing desperate for a new hope of economic development. In 1998, the pharmaceutical company Pfizer began construction of a major new research facility on the outskirts of the Fort Trumbull neighborhood of New London. Seeing an opportunity, the city of New London reactivated the New London Development Corporation, a private entity under the control of the city government, to consider plans to redevelop the Fort Trumbull neighborhood and encourage new economic activities that might be brought in by the Pfizer plant.^[3]

The development corporation created a development plan that included a resort hotel and conference center, a new state park, 80–100 new residences (which is now down to a mix of 14 rental townhouses and 66 apartments in a three-story building), and various research, office, and retail space. The plan divided the area into seven parcels, but did not specify the exact plans for development in any but the first parcel (the resort hotel and conference center). The city in 2000 approved the development plan and authorized the corporation to acquire the necessary land in the Fort Trumbull neighborhood.

Today, about half the homes in the former Fort Trumbull neighborhood are bulldozed and overgrown with weeds. The Pfizer facility can be seen in the background of this image.

Fort Trumbull was an older neighborhood, some 90 acres (364,000 m²) in size and including 115 residential and commercial lots. The development corporation offered to purchase all 115 lots; however, the owners of 15 of these properties did not wish to sell to the corporation. Of the 15 properties, ten were owned by occupants, and five by investors. Nine owners, not all of whom were full-time residents, were the petitioners in this case; the lead plaintiff, Susette Kelo, owned a small home on the Thames River in the development area.

The city of New London chose to exercise its power of eminent domain. The city ordered the development corporation, a private entity acting as the city's legally appointed agent, to condemn the 15 holdout owners' lots.

[edit] The case in the Connecticut courts

The owners sued the city in Connecticut courts, arguing that the city had misused its eminent domain power. The power of eminent domain is limited by the Fifth and Fourteenth Amendments to the United States Constitution. The Fifth Amendment, which restricts the actions of the federal government, says in part that "private property [shall not] be taken for public use, without just compensation"; under Section 1 of the Fourteenth Amendment, this limitation is also imposed on the actions of U.S. state and local governments. Kelo and the other appellants argued that economic development, the stated purpose of the Development Corporation, did not qualify as public use.

[edit] Certiorari to the U.S. Supreme Court

This case was the first major eminent domain case heard at the Supreme Court since 1984. In that time, states and municipalities had slowly extended their use of eminent domain, frequently to include economic development purposes where applicable. In the Kelo case, there was an additional twist in that the development corporation was ostensibly a private entity; thus the plaintiffs argued that it was not constitutional for the government to take private property from one individual or corporation and give it to another, if the government was simply doing so because the repossession would put the property to a use that would generate higher tax revenue.

The first eminent domain case since Midkiff to reach the Supreme Court, Kelo became the focus of vigorous discussion and attracted numerous supporters on both sides. Some 40 amicus curiae briefs were filed in the case, 25 on behalf of the petitioners. Suzette Kelo's supporters ranged from the libertarian Institute for Justice (the lead lawyers) to the NAACP, AARP and the late Martin Luther King's Southern Christian Leadership Conference. The latter three groups signed an amicus brief arguing that eminent domain has often been used against politically weak communities with high concentrations of minorities and elderly.

[edit] Oral argument

The case was argued on February 22, 2005. The case was heard by only seven members of the court with Associate Justice Sandra Day O'Connor presiding, as Chief Justice William Rehnquist was recuperating from medical treatment at home and Associate Justice John Paul Stevens was delayed on his return to Washington from Florida; both absent Justices read the briefs and oral argument transcripts and participated in the case decision.

During oral arguments, several of the Justices asked questions that forecast their ultimate positions on the case. Justice Antonin Scalia, for example, suggested that a ruling in favor of the city would destroy "the distinction between private use and public use," asserting that a private use which provided merely incidental benefits to the state was "not enough to justify use of the condemnation power."

[edit] The Court's decision

[edit] Majority and concurring opinions

On June 23, 2005, the Supreme Court, in a 5–4 decision, ruled in favor of the City of New London. Justice John Paul Stevens wrote the majority opinion; he was joined by Justices Anthony Kennedy, David Souter, Ruth Bader Ginsburg and Stephen Breyer. Justice Kennedy penned a concurring opinion setting out more detailed standards for judicial review of economic development takings than that found in Stevens' majority opinion. In so doing, he contributed to the Court's trend of turning minimum scrutiny--the idea that government policy need only bear a rational relation to a legitimate government purpose--into a fact-based test.

In Hawaii Housing Authority v. Midkiff, 467 US 229 (1984), the Court had said that the government purpose under minimum scrutiny need only be "conceivable." In two 1996 cases, however, the Court clarified that concept. In Romer v. Evans, 517 US 620, the Court said that the government purpose must be "independent and legitimate." And in U.S. v. Virginia, 518 U.S. 515, the Court said the government purpose "must be genuine, not hypothesized or invented post hoc in response to litigation." Thus, the Court made it clear that, in the scrutiny regime established in West Coast Hotel v. Parrish, 300 US 379 (1937), government purpose is a question of fact for the trier of fact.

Kennedy fleshed out this doctrine in his Kelo concurring opinion, in which he sets out a program of civil discovery in the context of a challenge to an assertion of government purpose in the eminent domain context. However, he does not explicitly limit these criteria to eminent domain, nor to minimum scrutiny, suggesting that they may be generalized to all health and welfare regulation in the scrutiny regime. Because Kennedy signed on to the Court's majority opinion, his concurrence is not binding on lower courts. He writes:

"A court confronted with a plausible accusation of impermissible favoritism to private parties should [conduct]….a careful and extensive inquiry into ‘whether, in fact, the development plan [chronology]

[1.] is of primary benefit to . . . the developer…, and private businesses which may eventually locate in the plan area…,

[2.] and in that regard, only of incidental benefit to the city…[.]’"

Kennedy is also interested in facts of the chronology which show, with respect to government,

[3.] awareness of…depressed economic condition and evidence corroborating the validity of this concern…,

[4.] the substantial commitment of public funds…before most of the private beneficiaries were known…,

[5.] evidence that [government] reviewed a variety of development plans…[,]

[6.] [government] chose a private developer from a group of applicants rather than picking out a particular transferee beforehand and…

[7.] other private beneficiaries of the project [were]…unknown [to government] because the…space proposed to be built [had] not yet been rented…."

Kelo v. City of New London was not a case which established an entirely new law concerning eminent domain. While the decision was controversial, it was not the first time “public use” had been interpreted by the Supreme Court as “public purpose.” In the majority opinion, Justice Stevens wrote the "Court long ago rejected any literal requirement that condemned property be put into use for the general public" (545 U.S. 469). Thus precedent played an important role in the 5-4 decision of the Supreme Court. The Fifth Amendment was interpreted the same way as in Midkiff (467 U.S. 229) and other earlier eminent domain cases that reached the Supreme Court.

[edit] Dissenting opinions

Justice Sandra Day O'Connor wrote the principal dissent, joined by Chief Justice William Rehnquist, Justice Antonin Scalia, and Justice Clarence Thomas. Justice O'Connor objected to the fact that an unelected (therefore voter-unaccountable) private nonprofit corporation was the primary beneficiary of the government taking. As a result, the dissenting opinion suggested that the use of this takings power in a reverse Robin Hood fashion— take from the poor, give to the rich— would become the norm, not the exception: "Any property may now be taken for the benefit of another private party, but the fallout from this decision will not be random. The beneficiaries are likely to be those citizens with disproportionate influence and power in the political process, including large corporations and development firms." She argued that the decision eliminates "any distinction between private and public use of property — and thereby effectively delete[s] the words 'for public use' from the Takings Clause of the Fifth Amendment." ^{125 S.Ct. 2655, 2671}

Clarence Thomas also penned a separate originalist dissent, in which he argued that the precedents the court's decision relied upon were flawed and that "something has gone seriously awry with this Court's interpretation of the Constitution." He accuses the majority of replacing the Fifth Amendment's "Public Use" clause with a very different "public purpose" test: "This deferential shift in phraseology enables the Court to hold, against all common sense, that a costly urban-renewal project whose stated purpose is a vague promise of new jobs and increased tax revenue, but which is also suspiciously agreeable to the Pfizer Corporation, is for a 'public use.'" Thomas also made use of the argument presented in the NAACP/AARP/SCLC amicus brief on behalf of three low-income residents' groups fighting redevelopment in New Jersey, noting: "Allowing the government to take property solely for public purposes is bad enough, but extending the concept of public purpose to encompass any economically beneficial goal guarantees that these losses will fall disproportionately on poor communities. Those communities are not only systematically less likely to put their lands to the highest and best social use, but are also the least politically powerful."^[4]

[edit] Subsequent history

One of the few remaining houses in the Fort Trumbull neighborhood, September 1, 2006. Underneath the white paint can just barely be read the words "Thank you Gov. Rell for your support" and the web URLs of two organizations protesting over-use of eminent domain, Castle Coalition and Institute for Justice.

The same house, June 10, 2007. The "thank you" is still visible, but the some windows are broken and others are boarded up, and "No Trespassing" has been spray-painted on it, as well as the URLs being obscured by spray paint.

Following the decision, many of the plaintiffs expressed an intent to find other means by which they could continue contesting the seizure of their homes. However, the Supreme Court having disposed of the eminent domain issue, the only legal avenue left to Kelo and her fellow residents may be to contest the fairness of the amount that the city intends to pay for the land— the city has reportedly set aside $1.6 million to buy all 15 homes, and city officials believe that they will be in possession of the property within a few months.^[5] Soon after the decision, city officials announced plans to charge the residents of the homes for back rent for the five years since condemnation procedures began. The city contends that the residents have been on city property for those five years and owe tens of thousands of dollars of rent. The case was finally resolved when the City agreed to move Kelo's house to a new location. The controversy was eventually settled when the city paid substantial additional compensation to the homeowners.[2].

In June 2006 Governor M. Jodi Rell intervened with New London city officials proposing the homeowners involved in the suit be deeded property in the Fort Trumbull neighborhood so they may retain their homes.^[6] But two years after the Supreme Court decision nothing is happening on the ground and it appears doubtful whether the city's redevelopment project will proceed. In spite of the city's arguments to the Supreme Court about its state of decline that was said to justify this redevelopment project, the Fitch bond rating service gave New London's general obligation bonds a solid investment grade rating of AA-.

The wider effect of Kelo remains to be seen. It will have little effect in the eight states that specifically prohibit the use of eminent domain for economic development except to eliminate blight: Arkansas, Florida, Illinois, Kentucky, Maine, Montana, South Carolina and Washington^[7]. As of July 4, 2005, The Washington Times claims that the decision has spurred action by officials in Newark, New Jersey and Arnold, Missouri.^[8] As of August 4, 2005, Alabama has banned takings like those authorized by Kelo, while such laws have been proposed in sixteen states and are likely to be proposed in seven more. Additionally, Alabama, California, Florida, Michigan, New Jersey and Texas are all considering constitutional amendments for the same purpose. This is expected to be a pivotal issue in the 2006 elections.^[9] As of March 2006, the town of Scituate, Massachusetts, in its annual town meeting, voted to limit its own eminent domain power to cases where the property in question is seized only for public ownership and public use.^[10]

A study of more than 10,000 allegedly abusive uses of the eminent domain clause conducted by an organization that supported the landowners in the Kelo case supports the argument that, as predicted in the dissenting opinions, neighborhoods with low-income minority residents will be most likely to see the power of Kelo used. Other likely locations for use of Kelo power include older neighborhoods near waterfront or developed commercial areas and low- and middle-class areas in general.^[11]

Judge Richard Posner, University of Chicago Law School professor and widely respected scholar of law and economics, published an analysis of the Kelo decision. ^[12] Although Posner does not take a position as to whether Kelo was properly decided, he observes that the eminent domain power can play an important role in eliminating economic problems associated with holdout owners (an economic term). He says that eminent domain can properly be used to address holdouts even in transactions involving private parties, such as utilities or other entities. He observes, however, that the Court apparently did not consider whether there was in fact a holdout program or assess net effect of the development plan on economic welfare, and notes many of the difficulties and complexities of the issues.

On January 25, 2006, BB&T's Chairman and CEO John Alison, announced that it "will not lend to commercial developers that plan to build condominiums, shopping malls and other private projects on land taken from private citizens by government entities using eminent domain," holding that the ruling is morally objectionable and violates "basic rights". ^[13]

On February 7, 2006, a compromise was proposed by Mayor Beth Sabilia between the residents of Fort Trumbull and the City of New London under which four of the six residences would remain, and the other two would be relocated within the new proposed complex. Under this proposal, the city would gain the title to the disputed properties, and rent would be imposed in lieu of taxes.^[14]

On May 23, 2006, the city council of Hercules, California, voted unanimously to use the right of eminent domain to seize 17 acres owned by Wal-Mart. At a hearing preceding the decision, many dozens of residents spoke against Wal-Mart, complaining that the box stores economically depress an area by driving small shops bankrupt, and moving profits out of the local economy. The council applied the reasoning in the Kelo decision to pre-emptively prevent Wal-Mart from depressing the city's economy. It is unclear if Wal-Mart intends to take legal action against Hercules, California.

[edit] Public reaction

Opinion polls found that the public overwhelmingly disapproved of the ruling. A Christian Science Monitor online poll found that 93% disagreed with the ruling. Most other polls, depending on the question posed, reacted negatively in the 65% to 97% range.^{[citation needed]} Opposition to the ruling was stated by popular groups such as AARP, the NAACP, the Libertarian Party, and the Institute for Justice. Many owners of family farms also disapproved of the ruling, as they saw it as an avenue by which cities could seize their land for private developments. The grassroots lobbying group American Conservative Union and The New Media Journal described the decision as judicial activism, as did numerous blogs. [3] [4] A group of New London residents formed a local political party, One New London [5], to combat the takings. While unsuccessful in gaining control of the New London City Council they gained two seats, and continue to try to take over New London City Council to rectify the Ft. Trumbull takings.

[edit] Presidential reaction

On June 23, 2006, the first anniversary of the original decision, President George W. Bush issued an executive order [6] instructing the federal government to use eminent domain "...for the purpose of benefiting the general public and not merely for the purpose of advancing the economic interest of private parties to be given ownership or use of the property taken." [7] However, eminent domain is often exercised by local and state governments; the order may thus have little overall effect.

[edit] Congressional reaction

On June 27, 2005, Senator John Cornyn (R-TX) introduced legislation, the "Protection of Homes, Small Businesses, and Private Property Act of 2005" (S.B. 1313), to limit the use of eminent domain for economic development. The operative language (1) prohibits the federal government from exercising eminent domain power if the only justifying "public use" is economic development; and (2) imposes the same limit on state and local government exercise of eminent domain power "through the use of Federal funds." Similar bills have subsequently been put forth in the House of Representatives by Congressman Dennis Rehberg (R-MT), Tom DeLay (R-TX), and John Conyers (D-MI) with James Sensenbrenner (R-WI). As some small-scale eminent domain condemnations (including notably those in the Kelo case) can be local in both decision and funding, it is unclear how much of an effect the bill would have if it passed into law.^[15]

The Kelo decision also drew strong condemnation from Texas Congressman Ron Paul. Reacting to the court ruling, Ron Paul wrote, "It's clear that many political and business interests are only too willing to drive people literally out of their homes to make way for the grand schemes of those in power...Now one year removed from the notorious Kelo decision by the Supreme Court, Americans are still reeling from the shock of having our nation's highest tribunal endorse using government power to condemn private homes to benefit a property developer." link

[edit] The promised economic benefits fail to materialize

In November of 2007, it was reported that the economic benefits that had been promised by supporters of the Kelo ruling had failed to materialize. Corcoran Jennison, the developer, had failed to obtain financing by the promised deadline, and was said to be technically in default. [8]

[edit] Other Reactions

By July 2007, 42 states had enacted some type of reform legislation in response to the Kelo decision. 21 of those states enacted laws that severely inhibit the takings allowed by the Kelo decision, while 21 others enacted laws that place some limits on the power of municipalities to invoke eminent domain for economic development. The remaining eight states have not passed laws to limit the power of eminent domain for economic development. ^[16]

[edit] Arizona

Proposition 207 passed in 2006. The Private Property Rights Protection Act [9]

[edit] New Hampshire

Subsequent to this decision, there was widespread outrage across the US. A California developer and libertarian, Logan Darrow Clements scooped a similar proposal by New Hampshire libertarians to seize Justice Souter's 'blighted' home in Weare, New Hampshire, via eminent domain in order to build a "Lost Liberty Hotel" which he said would feature a "Just Desserts Cafe". Officials of the Libertarian Party of New Hampshire (LPNH) and the Coalition of New Hampshire Taxpayers had been eyeing the Justice's property to build a Constitution Park. A few weeks later, LPNH Vice-Chair Mike Lorrey discovered that Justice Breyer owned an extensive vacation estate in Plainfield, NH, and announced on the New Hampshire Public Radio show The Exchange focusing on eminent domain that LPNH would be pursuing their Constitution Park concept with Breyer's property in mind. Lorrey and Clements both advocated an amendment to New Hampshire's Constitution limiting eminent domain, which passed New Hampshire's legislature on March 24, 2006. The text of the amendment is as follows: "No part of a person's property shall be taken by eminent domain and transferred, directly or indirectly, to another person if the taking is for the purpose of private development or other private use of the property.[10]" It passed by an overwhelming margin in the 2006 general election.[11]

[edit] California

Proposition 90 failed in the November 2006 election [12]. The initiative also included language requiring that government pay financial compensation to any property owners who could successfully argue that regulation caused them significant economic loss. Subsequently, Proposition 99 passed in the June 2008 election. It amends the state constitution to prohibit "state and local governments from using eminent domain to acquire an owner-occupied residence [if the owner has occupied the residence for at least one year], as defined, for conveyance to a private person or business entity", subject to some exceptions.

[edit] Florida

Florida passed a 2006 ballot measure amending the Florida Constitution to restrict use of eminent domain.[13] The amendment says in part:

Private property taken by eminent domain [...] may not be conveyed to a natural person or private entity except as provided by general law passed by a three-fifths vote of the membership of each house of the Legislature.

[edit] Iowa

The Iowa Legislature passed a 2006 bill restricting the use of eminent domain for economic development. Gov. Tom Vilsack (D) vetoed the bill [14], prompting the first special session of the Iowa Legislature in more than 40 years. The veto was overridden by votes of 90-8 in the Iowa House and 41-8 in the Iowa Senate. [15]

[edit] Ohio

An attempted use of eminent domain was brought before the Ohio supreme court in Norwood, Ohio v. Horney. The Supreme Court of Ohio held in favor of the property owners.

[edit] Michigan

Michigan passed a restriction on the use of eminent domain in November 2006, Proposition 4, 80% to 20%. The text of the ballot initiative was as follows [16]

A PROPOSED CONSTITUTIONAL AMENDMENT TO PROHIBIT GOVERNMENT FROM TAKING PRIVATE PROPERTY BY EMINENT DOMAIN FOR CERTAIN PRIVATE PURPOSES The proposed constitutional amendment would:
• Prohibit government from taking private property for transfer to another private individual or business for purposes of economic development or increasing tax revenue.
• Provide that if an individual’s principal residence is taken by government for public use, the individual must be paid at least 125% of property’s fair market value.
• Require government that takes a private property to demonstrate that the taking is for a public use; if taken to eliminate blight, require a higher standard of proof to demonstrate that the taking of that property is for a public use.
• Preserve existing rights of property owners.

[edit] See also

Wikinews has related news:

Man calls for seizure of Justice Souter home, under eminent domain ruling

• List of United States Supreme Court cases, volume 545
• List of United States Supreme Court cases
• Lost Liberty Hotel
• Constitution Park

[edit] Further reading

• Joshua U. Galperin, "A Warning To States, Accepting this Invitation May be Hazardous to Your Health (Safety and Public Welfare): An Analysis of Post-Kelo Legislative Activity." 31 Vermont Law Review 663 (Spring 2007).

• John Ryskamp, The Eminent Domain Revolt: Changing Perceptions in a New Constitutional Epoch, New York: Algora Publishing, 2006.

[edit] References

Gideon Kanner, Kelo v. New London: Bad Law, Bad Policy and Bad Judgment, 38 The Urban Lawyer 201 (Spring 2006)

[edit] External links

Wikisource has original text related to this article:

Kelo v. City of New London

• Full text of the decision courtesy of Findlaw.com
• Text of the lower court decision
• The Supreme Court Docket for the case and list of amicus briefs
• Transcript of the oral argument in this case
• Property Rights and Eminent Domain: The Mighty Myths of the Kelo Case
• Congress works to blunt court decision
• Lessons From the Kelo Decision, essay by Congressman Ron Paul on LewRockwell.com
• Article in the New York Times: States Curbing Right to Seize Private Homes
• Barry Yeoman, Whose House Is It Anyway?, AARP: The Magazine

• Kelo v. City of New London is at coordinates 41°20′39″N 72°05′50″W / 41.344082, -72.097220 (Kelo v. City of New London)Coordinates: 41°20′39″N 72°05′50″W / 41.344082, -72.097220 (Kelo v. City of New London)
• Limit Eminent Domain organization gathering signatures for the California Eminent Domain Limitations Act
• NCSL: Eminent Domain