Martin v. Creasy - 360 U.S. 219 (1959)
U.S. Supreme Court
Martin v. Creasy, 360 U.S. 219 (1959)
Martin v. Creasy
Argued April 2, 1959
Decided June 8, 1959
360 U.S. 219
Respondents owned property abutting a section of highway in Pennsylvania which was about to be designated as a "limited access highway" under authority of a Pennsylvania statute which provides that the owners of property affected by the designation of a "limited access highway" shall be entitled "only to damages arising from an actual taking of property," and not for "consequential damages where no property is taken." They sued in a Federal District Court for injunctive relief and a judgment declaring the statute unconstitutional. The District Court stayed its proceedings to permit the parties to seek a determination of their rights under the Act in the state courts. They brought an equity suit in a state court, which held that the Act provides a method by which every property owner may have it decided whether he is entitled to compensation, and, if so, for what and in what amounts, and that their constitutional rights, whatever they may be, will be protected. The State Supreme Court affirmed. Thereafter, the District Court concluded that the State Legislature did not intend to compensate abutting landowners whose rights of access to an existing highway are destroyed by its designation as a limited access highway, and that the Act violated the Due Process Clause of the Fourteenth Amendment, and it permanently enjoined the Governor and the Secretary of Highways from proceeding further.
Held: the circumstances were such that the District Court should have declined to adjudicate this controversy. Pp. 360 U. S. 220-225.
(a) The desirability of avoiding unseemly conflict between two sovereignties, the unnecessary impairment of state functions, and the premature determination of constitutional questions should have led the District Court to stay its hand. Pp. 360 U. S. 223-224.
(b) Another reason why the District Court should have stayed its hand is to be found in the complex and varying effects which the contemplated state action may have upon different landowners. Pp. 360 U. S. 224-225.
(c) There is no reason to suppose that the State will not accord full constitutional scope to the statutory phrase "actual taking of property"; but, should it fail to do so, recourse may be had to this Court. P. 360 U. S. 225.
160 F. Supp. 404, reversed.