Term: 2004
Docket: 04-163
Linda Lingle, Governor Of Hawaii, Et Al. v. Chevron U.s.a. Inc.
- Pro
04-163 LINGLE V. CHEVRON U.S.A., INC. DECISION BELOW: 363 F3d 846 CERT. GRANTED 10/12/2004 QUESTION PRESENTED: 1. Whether the Just Compensation Clause authorizes a court to invalidate state economic legislation on its face and enjoin enforcement of the law on the basis that the legislation does not substantially advance a legitimate state interest, without regard to whether the challenged law diminishes the economic value or usefulness of any property. 2. Whether a court, in determining under the Just Compensation Clause whether state economic legislation substantially advances a legitimate state interest, should apply a deferential standard of review equivalent to that traditionally applied to economic legislation under the Due Process and Equal Protection Clauses, or may instead substitute its judgment for that of the legislature by determining de novo, by a preponderance of the evidence at trial, whether the legislation will be effective in achieving its goals. LOWER COURT CASE NUMBER: 02-15867
The U.S. Supreme Court case Linda Lingle, Governor of Hawaii, et al. v. Chevron U.S.A Inc., 2004 revolved around a dispute over the constitutionality of a Hawaiian statute that limited the rent oil companies could charge dealers leasing their service stations. The law was enacted to prevent monopolistic practices and ensure fair business competition in Hawaii's petroleum market. Chevron challenged this law as an unconstitutional taking without just compensation under the Fifth Amendment's Takings Clause because it did not serve any legitimate public purpose and instead transferred wealth from one private party to another. In its ruling, however, the Supreme Court unanimously overturned previous decisions by lower courts which had sided with Chevron on grounds that economic regulation effects an unconstitutional taking if it does not "substantially advance" legitimate state interests - a test derived from earlier cases involving land-use regulations rather than economic legislation like price or rate setting laws. Instead, Justice Sandra Day O'Connor writing for all nine justices held that whether such regulation substantially advances a state interest is irrelevant to determining if there has been a 'taking'. Rather what matters is whether government action appropriates private property for public use without paying just compensation – something she said hadn't occurred here since no physical invasion or denial of economically beneficial use happened due to this rent cap.
In the case of Linda Lingle, Governor of Hawaii, et al. v. Chevron U.S.A. Inc., there was no dissenting opinion recorded as the decision was unanimous (9-0) in favor of Chevron U.S.A. Inc., reversing and remanding the previous court's decision. The Supreme Court ruled that a Hawaiian statute limiting rent oil companies could charge dealers did not constitute a taking under the Fifth Amendment's Takings Clause because it did not transfer wealth to the public or risk doing so in any significant way.
