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Project Curia
Supreme Court decisions
No. 22-913Apr 16, 2024LawVacated and remanded

The question

Whether property owners may pursue a claim for just compensation under the Takings Clause of the Fifth Amendment when state law already provides an inverse-condemnation cause of action to vindicate that right.

DeVillier v. Texas

What the Court decided

The Court vacated the Fifth Circuit and remanded. DeVillier and the other property owners may pursue their Takings Clause claims through the inverse-condemnation cause of action that Texas law already provides. Because state law supplies a vehicle to seek just compensation against the State under both the Texas Constitution and the Takings Clause, this case does not present the situation of a property owner left with no cause of action, and the Court declined to decide whether the Takings Clause itself creates one.

How the justices split

Unanimous
In favor 9
Thomas
Roberts
Alito
Sotomayor
Kagan
Gorsuch
Kavanaugh
Barrett
Jackson

The Court's opinion

Thomas, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson

The Court held that the property owners may proceed on their Takings Clause claims through the inverse-condemnation cause of action Texas law already provides. Constitutional rights do not typically carry a built-in cause of action and are asserted through an independent one designed for that purpose. Because Texas law lets property owners seek just compensation against the State under both the Texas Constitution and the Takings Clause, this case does not present a plaintiff with no cause of action, and the Court declined to decide whether the Takings Clause creates one by its own force. It vacated and remanded so the owners could proceed under state law.

How we know · 5 sourced claims
  • The decision was unanimous, with Justice Thomas delivering the opinion for the Court.

    Source: syllabus, lineup

  • The Court held that DeVillier and the other property owners may pursue their Takings Clause claims through the cause of action available under Texas law.

    Source: syllabus, Held

  • The Court declined to decide whether the Takings Clause itself creates a cause of action, finding it imprudent because Texas law already provides an inverse-condemnation vehicle.

    Source: syllabus, Held

  • The Fifth Circuit judgment (53 F. 4th 904) was vacated and remanded.

    Source: syllabus, Held

  • The dispute arose after Texas installed a median barrier along Interstate 10 that flooded the petitioners' land, which they alleged effected a taking requiring just compensation.

    Source: syllabus, Held

Read the opinion on supremecourt.gov