Goldblatt v. Hempstead

Rule of Law:

A state or local government regulation enacted under the police power to protect public health and safety is not an unconstitutional taking under the Fourteenth Amendment, even if it prohibits the most beneficial use of a property, so long as the regulation is reasonably necessary to achieve its purpose and the property owner fails to prove it causes a significant economic loss.

Facts:

• Appellant Goldblatt owned a 38-acre tract of land in the Town of Hempstead.
• Since 1927, the property had been continuously used for mining sand and gravel by appellant Builders Sand and Gravel Corporation.
• This mining operation involved excavating below the water table, which created a 20-acre lake with an average depth of 25 feet.
• Over the decades, the town's population grew substantially around the excavation site.
• By the time of the litigation, more than 2,200 homes and four public schools with 4,500 students were located within a 3,500-foot radius of the lake.
• In 1958, the Town of Hempstead enacted a safety ordinance that prohibited any excavation below the water table and required any existing excavation to be refilled.
• This ordinance effectively prevented Goldblatt from continuing the sand and gravel mining operation on the property.

Procedural Posture:

• The Town of Hempstead brought an action in a New York state trial court to enjoin Goldblatt and Builders Sand and Gravel Corporation from further mining in violation of a town safety ordinance.
• The trial court found the ordinance to be a valid exercise of police power and issued the injunction.
• Goldblatt, as appellant, appealed to the Appellate Division of the New York Supreme Court, which affirmed the trial court's judgment.
• Goldblatt, as appellant, then appealed to the New York Court of Appeals, the state's highest court, which affirmed the lower court's decision.
• The United States Supreme Court noted probable jurisdiction to review the case.