Rose Mary Knick, Petitioner v. Township of Scott, Pennsylvania

Summary

The Supreme Court held that a government violates the Takings Clause—and the owner acquires an actionable Fifth Amendment claim—the moment it takes property without paying just compensation, so the owner may sue under 42 U.S.C. §1983 immediately, without first pursuing state inverse condemnation procedures. It accordingly overruled the state-litigation requirement of Williamson County Regional Planning Comm'n v. Hamilton Bank, which had forced takings plaintiffs into state court first and, combined with the San Remo preclusion trap, left many unable ever to reach federal court; the stare decisis factors of defective reasoning, unworkability, inconsistency with related decisions, and absent reliance all favored abandonment. The Court vacated the Third Circuit's judgment and remanded for further proceedings. Justice Thomas concurred to emphasize that just compensation is a prerequisite to a valid exercise of the eminent domain power, while Justice Kagan, joined by Justices Ginsburg, Breyer, and Sotomayor, dissented, contending that the decision upends a century of takings precedent and betrays judicial federalism.