Sunday, April 14, 2013

Lucas v. South Carolina Coastal Council case brief

Lucas v. South Carolina Coastal Council case brief summary
505 U.S. 1003

CASE SYNOPSIS:
Petitioner landowner sought review of the judgment of the Supreme Court of South Carolina concluding that petitioner was not entitled to compensation from the State under the Takings Clause of the Fifth Amendment.

OVERVIEW: The landowner purchased two residential lots on which he intended to build homes. In 1988, State enacted the Beachfront Management Act, S. C. Code Ann. § 48-39-250 et seq., which barred the landowner from erecting any permanent habitable structures on his two parcels. A state trial court found that this prohibition rendered the landowner's parcels valueless. The landowner asserted the effect of the Act on the value of the lots accomplished a taking under the Fifth and Fourteenth Amendments.

HOLDING:
The court held that where a state seeks to sustain a regulation that deprives land of all economically beneficial use, it may resist compensation only if the logically antecedent inquiry into the nature of the owner's estate showed that the proscribed use interests were not part of his title to begin with.

OUTCOME: The court reversed the judgment of the state supreme court denying compensation to the landowner under the Takings Clause of the Fifth Amendment and remanded the case because the regulation's effect on the landowner's property value was relevant.

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