Hawaii Housing Authority v. Midkiff

Citation. 467 U.S. 229, 104 S. Ct. 2321, 81 L. Ed. 2d 186, 1984 U.S.

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.

Facts. The land ownership of the Hawaiian Islands is concentrated in a small group of descendants of Polynesian chieftains. They subsequently lease their land to a multitude of homeowners by parcel. In order to spread land ownership to more people, Petitioner could condemn the property and sell the parcels to the lessees to “effectuate the public purposes.” Sale prices were set by either a condemnation trial or by negotiation between the lessor and lessees. The price had to equal the fair market value of the owner’s leased fee interest and Petitioner could not sell more than one parcel to any one purchaser or lessee.

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.

Discussion. The social evil is the concentration of landownership in only a small group of people. The result of this was a monopolized real estate market that improperly inflated rates. So, the Supreme Court of the United States (Supreme Court) determined that the exercise of eminent domain was an appropriate action by the state to rectify this public h