Sunday, April 14, 2013

Penn Central Transportation Company v. City of New York case brief

Penn Central Transportation Company v. City of New York case brief summary
438 U.S. 104

CASE SYNOPSIS:
Plaintiffs appealed a judgment from the Court of Appeals of New York holding that defendants had not taken property without just compensation and did not arbitrarily deprive plaintiffs of their property without Fourteenth Amendment due process of law in a case involving the application of the city's Landmarks Preservation Law, N.Y. City Admin. Code, ch. 8-A, § 205-1.0 et seq. (1976), to Grand Central Terminal.

OVERVIEW: The court affirmed the judgment holding that defendants had not taken plaintiffs' property without just compensation and did not arbitrarily deprive plaintiffs of their property without Fourteenth Amendment due process of law.

HOLDING:
The Court held that plaintiffs could not establish a "taking" simply by showing that they had been denied the ability to exploit a property interest that they had believed was available for development. The court noted that landmark laws were not like discriminatory or "reverse spot" zoning.

ANALYSIS:
The Landmarks Law did not interfere in any way with the terminal's present uses and plaintiffs' primary expectation concerning the use of the parcel. The restrictions imposed were substantially related to the promotion of the general welfare and not only permitted reasonable beneficial use of the landmark site, but also afforded plaintiffs opportunities further to enhance not only the terminal site, but also other properties.

OUTCOME: The judgment holding that defendants did not take plaintiffs' property without just compensation and did not deprive plaintiffs of their property without Fourteenth Amendment due process of law was affirmed because the application of the law had not effected a taking and the restrictions imposed were substantially related to the promotion of the general welfare and permitted reasonable beneficial use.

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