First English Evangelical Lutheran Church v. Los Angeles County facts for kids
Quick facts for kids First English Evangelical Lutheran Church v. Los Angeles County |
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| Argued January 14, 1987 Decided June 9, 1987 |
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| Full case name | First English Evangelical Lutheran Church of Glendale v. County of Los Angeles, California |
| Citations | 482 U.S. 304 (more)
107 S. Ct. 2378; 96 L. Ed. 2d 250; 1987 U.S. LEXIS 2606; 55 U.S.L.W. 4781; 26 ERC (BNA) 1001; 17 ELR 20787
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| Argument | Oral argument |
| Holding | |
| The complete destruction of the value of property constituted a taking under the Fifth Amendment even if that taking was temporary and the property was later restored. | |
| Court membership | |
| Case opinions | |
| Majority | Rehnquist, joined by Brennan, White, Marshall, Powell, Scalia |
| Dissent | Stevens, joined by Blackmun, O'Connor (parts I, III) |
| Laws applied | |
| U.S. Const. amends. V, XIV | |
This case, First English Evangelical Lutheran Church v. Los Angeles County, was an important decision by the U.S. Supreme Court in 1987. The Court decided that if the government temporarily stops someone from using their land, and this makes the land lose all its value, it's like the government "taking" the property. When this happens, the government must pay the owner, even if the restriction is only for a short time. This is based on the Fifth Amendment of the U.S. Constitution.
Contents
Why This Case Was Important
This Supreme Court decision made it clear that even a temporary rule by the government can be considered a "taking" of property. If a government rule prevents a property owner from using their land at all, even for a short time, the owner might be owed money. This is called "just compensation."
The Fifth Amendment and Takings
The Fifth Amendment says that private property cannot be "taken for public use, without just compensation." This means if the government needs your land for something like a road or a park, they have to pay you a fair price for it. This case explored what counts as a "taking" when the government doesn't physically take the land, but makes a rule that affects its use.
What Happened Before the Case
The First English Evangelical Lutheran Church owned a special place called Lutherglen. It was a retreat center for children with disabilities. Lutherglen was located in the Angeles National Forest.
The Flood and the New Rule
In 1978, a big flood hit the area. It destroyed all the buildings at Lutherglen. After the flood, Los Angeles County made a new rule. This rule stopped anyone from building in the area where Lutherglen was, because it was a floodplain. A floodplain is an area of land next to a river that is likely to flood.
The Church's Lawsuit
The church felt that this new rule stopped them from using their land at all. They sued Los Angeles County, asking for money because they believed the county's rule had "taken" their property. This is known as "inverse condemnation," where a property owner sues the government because a rule has effectively taken their property.
A lower court did not agree with the church. In California at the time, if a rule was too strict, the government usually just had to remove the rule. They didn't have to pay money for the time the rule was in place. The church's case then went up to the Supreme Court.
The Supreme Court's Decision
The U.S. Supreme Court looked at the case. Six out of nine justices agreed with the church. They sent the case back to the lower courts to be looked at again.
Why the Court Agreed with the Church
Chief Justice William Rehnquist wrote the main opinion for the Court. He explained that if a government rule completely stops someone from using their property, even for a short time, it's like a temporary "taking." And if it's a taking, the government must pay the owner "just compensation" for that time.
The Court believed that if the government could just cancel a rule without paying, it wouldn't be fair to property owners. It would mean the government could temporarily take away someone's property rights without any cost. The Court compared this to times during World War II when the government temporarily used private property for the war effort. In those cases, the government had to pay the owners.
The Dissenting Opinion
Three justices disagreed with the majority decision. Justice John Paul Stevens wrote the dissenting opinion. Justices Harry Blackmun and Sandra Day O'Connor joined him.
Concerns of the Dissenters
The dissenting justices worried that this decision would lead to many more lawsuits against local governments. They also pointed out that the church's case might not be very strong anyway. The severe floods might have made it impossible to rebuild Lutherglen, even without the county's rule.
Justice Stevens also talked about the difference between the government physically taking land and making a rule that affects land use. He felt that rules are more complex and should not always be treated the same as a physical taking. He believed that existing legal processes were enough to protect property owners from unfair rules.
