Hadacheck v. Sebastian
Citation and Court
239 U.S. 394 (1915), Supreme Court of the United States
Facts
Hadacheck operated a brickyard in Los Angeles that predated the surrounding residential development. As the city grew around the brickyard, the Los Angeles City Council enacted an ordinance prohibiting the operation of brickyards in the area. Hadacheck’s land was worth far more as a brickyard than for any other purpose; the ordinance effectively destroyed that use. He was arrested for violating the ordinance and challenged it as an unconstitutional taking.
Issue
Whether a zoning ordinance that prohibits a previously established and otherwise lawful business use of land constitutes an unconstitutional taking of property without just compensation.
Holding
The Supreme Court unanimously upheld the ordinance, holding that it was a valid exercise of the police power to abate a nuisance-like use and did not constitute a taking requiring compensation.
Rule / Doctrine
The government’s power to regulate land use under the police power extends to prohibiting uses that are harmful or injurious to public health, safety, and welfare, even if the regulation destroys significant economic value. A regulation that is a legitimate exercise of the nuisance-abatement power does not constitute a compensable taking, even when it severely reduces the value of the property.
Significance
Hadacheck v. Sebastian is one of the earliest and most important Supreme Court cases on the police power versus takings distinction. It established the principle that the government may prohibit harmful land uses without paying compensation, and is contrasted with Penn Coal Co. v. Mahon (1922) to illustrate the limits of the nuisance-abatement rationale.