Chicago, Burlington, and Quincy Railroad Inc. v. City of Chicago (Bill of Rights Rail 10)
Legal Issues
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The Facts
Chicago, Burlington, and Quincy Railroad owned land in Chicago. The City of Chicago, acting under state authority, constructed a public street grade that effectively lowered the railroad's property value and access without compensation. The railroad sued the City for damages, arguing the state had taken its property without just compensation in violation of the Fifth Amendment.
The Issue
Whether the Fifth Amendment's takings requirement applies to the states through the Fourteenth Amendment's Due Process Clause. Whether the state's construction of a street grade constituted a taking of the railroad's property requiring just compensation.
The Rules
nor shall private property be taken for public use, without just compensation
nor shall any State deprive any person of life, liberty, or property, without due process of law
Due process under the Fourteenth Amendment requires states to provide just compensation when taking private property for public use
The Application
The Court found that the City's construction of the public street grade substantially diminished the railroad's property value and access without providing any compensation, thereby constituting a taking of property for public use. Because the City acted under state authority to accomplish a public purpose, the Court recognized this as precisely the type of governmental action the Just Compensation Clause was designed to prevent, uncompensated appropriation of private property, and held that this constitutional protection must apply equally to state governments through the Fourteenth Amendment. The Court thus held the state liable to compensate the railroad, establishing that the Fifth Amendment's takings guarantee operates as an enforceable constraint on state action and cannot be circumvented by the state's own constitutional framework.
The Conclusion
**The Supreme Court held 7-1 that the Fifth Amendment's just compensation requirement is incorporated into the Fourteenth Amendment and applies to the states.** The Court found that the state's actions substantially diminished the railroad's property value and constituted a taking requiring just compensation. This decision established that due process under the Fourteenth Amendment includes protection against uncompensated takings of private property.
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