Background
The City of Baltimore entered an agreement with a developer to redevelop 13.8 acres in the Poppleton neighborhood, using eminent domain to acquire the land. The project stalled, leaving the land vacant and neglected. Six adjacent property owners and a community organization sued, alleging the takings were unconstitutional and that the blight constituted a private nuisance. The district court dismissed all claims, finding the plaintiffs lacked standing for the takings claim and failed to state a nuisance claim.
The court’s reasoning
The court held that the plaintiffs satisfied Article III standing for their takings claim because they alleged a concrete injury in fact through the loss of property value. However, the court clarified that standing does not equate to a valid claim on the merits. To state a takings claim, a plaintiff must own the property that was taken. Since the plaintiffs did not own the condemned land, their takings claim failed. Regarding the state law nuisance claim, the court found the district court erred by reaching the merits without first deciding whether to exercise supplemental jurisdiction. Because all federal claims were dismissed early in the case, the district court should have declined supplemental jurisdiction and dismissed the state claim without prejudice.
The Takings Clause does not provide the plaintiffs with a mechanism to challenge the taking of their former neighbors’ properties because holding a protected property interest in taken property is an essential element of any takings claim.
Poppleton Now Community Association, Inc. v. La Cite Development, LLC, 2026 U.S. App. LEXIS 10234 (4th Cir. May 4, 2026)
What it means going forward
The decision clarifies that while adjacent property owners may have standing to sue over takings based on economic harm, they cannot succeed on the merits without owning the taken property. It also reinforces the procedural requirement for federal courts to decline supplemental jurisdiction over state claims when federal claims are dismissed at the pleading stage.
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