Brief Fact Summary. The Petitioner, Hawaii Housing Authority (Petitioner), forced landowners such as the Respondent, Midkiff (Respondent), to sell parcels of their land to those who were leasing the land. This was done in an effort to spread land ownership more evenly amongst the islands’ inhabitants.
Synopsis of Rule of Law. Ones property may not be taken for the benefit of another private person without a justifying public purpose, even though compensation was paid.
Issue. Is the transferring of title from lessors to lessees in order to reduce the concentration of ownership of fees simple a taking by the state of Hawaii?
Held. No. The Hawaii Legislature enacted its Land Reform Act not to benefit a particular class of individuals, but to attack perceived evils of concentrated property ownership in Hawaii. This is a legitimate public purpose.
The relevant inquiry is not whether there is a bare, though unlikely, possibility that state courts might render adjudication of the federal question unnecessary.View Full Point of Law