Knick v. Township of Scott

Rose Mary Knick owned a small rural cemetery in Scott Township, Pennsylvania. The township passed an ordinance requiring all cemeteries to be open to the public during daylight hours and kept in good condition. Knick contended this ordinance took her property without just compensation, violating the Fifth Amendment. She filed a federal lawsuit under 42 U.S.C. § 1983. Lower courts dismissed the suit, citing Williamson County v. Hamilton Bank, which mandated that property owners seek compensation through state procedures before bringing a federal claim. The U.S. Supreme Court granted certiorari. In a 5-4 decision delivered by Chief Justice Roberts on June 21, 2019, the Court overruled Williamson County. It held that a Fifth Amendment violation occurs at the moment of an uncompensated taking, giving rise to an immediate federal cause of action without requiring exhaustion of state remedies.

The Supreme Court overruled Williamson County Regional Planning Commission v. Hamilton Bank. It held that a property owner has a valid federal takings claim immediately upon an uncompensated taking and may sue in federal court without first exhausting state compensation remedies.

Whether a property owner must first seek just compensation through state court procedures before bringing a federal takings claim under the Fifth Amendment, or can file directly in federal court.

The decision removed a significant procedural hurdle for property owners, allowing direct access to federal courts for takings claims. It strengthened constitutional property rights protections, altered litigation strategies against local land-use regulations, and shifted takings jurisprudence toward greater federal judicial oversight.