Knick v. Township of Scott, 139 S. Ct. 2162

Rose Mary Knick owns 90 acres in Pennsylvania; a local ordinance required private cemeteries to be open to the public and authorized code officers to enter private property to locate cemeteries.
A Township officer cited Knick for violating the ordinance after finding gravemarkers; the Township stayed enforcement during Knick's state-court action and withdrew the notice, so the state court declined equitable relief for lack of ongoing enforcement.
Knick filed a federal § 1983 action alleging the ordinance effected a taking without just compensation; the District Court dismissed under Williamson County, and the Third Circuit affirmed.
The Supreme Court granted certiorari to reconsider Williamson County’s rule that plaintiffs must first pursue state inverse-condemnation remedies before bringing a federal takings claim.
The Court held Williamson County’s state-litigation requirement was wrong and overruled it, ruling that an uncompensated taking gives rise to a § 1983 claim immediately on the taking.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a property owner has a federal takings claim under § 1983 when the government takes property without having first denied compensation in state proceedings	Knick: the Takings Clause is self-executing; a taking without compensation is a constitutional violation at the time of the taking, permitting immediate federal § 1983 suit	Township/Williamson County: no Fifth Amendment violation exists until the owner has used the State's adequate procedures and been denied just compensation (state-litigation requirement)	Held for Knick: overruling Williamson County, the Court held a Fifth Amendment violation occurs at the time of an uncompensated taking and may be brought under § 1983 without prior state-court exhaustion
Whether Williamson County’s state-litigation rule should be retained under stare decisis	Knick: Williamson County is inconsistent with long-standing takings doctrine, unworkable (creates San Remo preclusion trap), and has poor reasoning	Respondents: Williamson County follows a century of precedent allowing post-taking remedies to satisfy the Clause and promotes federalism and workability	Held: Court found Williamson County wrongly decided, unworkable, inconsistent with precedent, and overruled it

Williamson County Regional Planning Comm'n v. Hamilton Bank of Johnson City, 473 U.S. 172 (Sup. Ct. 1985) (established state-litigation requirement later overruled)
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005) (held state inverse-condemnation judgments have preclusive effect in later federal suits)
First English Evangelical Lutheran Church v. County of Los Angeles, 482 U.S. 304 (1987) (held the Takings Clause gives rise to a compensable claim for temporary regulatory takings and emphasized the self-executing nature of the Clause)
Jacobs v. United States, 290 U.S. 13 (1933) (Tucker Act claims rest on the Fifth Amendment and compensation relates back to the time of taking)
Ruckelshaus v. Monsanto Co., 467 U.S. 986 (1984) (held injunction inappropriate where a legal remedy for compensation exists; language influenced Williamson County)
Parratt v. Taylor, 451 U.S. 527 (1981) (due process post-deprivation remedy case relied upon in Williamson County but factually distinct)
United States v. Causby, 328 U.S. 256 (1946) (Tucker Act/federal takings jurisprudence recognizing the taking as the event giving rise to compensation)
United States v. Dow, 357 U.S. 17 (1958) (compensation claim arises at the time of the taking)
San Diego Gas & Elec. Co. v. San Diego, 450 U.S. 621 (1981) (partial dissent reasoning on timing of compensation and constitutional violation referenced)