Hawaii Housing Authority v. Midkiff
E579572
Hawaii Housing Authority v. Midkiff is a 1984 U.S. Supreme Court case that broadly interpreted the Fifth Amendment’s Public Use Clause to allow government use of eminent domain for economic and social policy goals, such as breaking up concentrated land ownership.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Hawaii Housing Authority v. Midkiff canonical | 1 |
| Hawaii Housing Authority, et al. v. Midkiff, et al. | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T6250622 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Hawaii Housing Authority v. Midkiff Context triple: [Kelo v. City of New London, appliedPrecedent, Hawaii Housing Authority v. Midkiff]
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A.
Hawaii v. Office of Hawaiian Affairs
Hawaii v. Office of Hawaiian Affairs is a 2009 U.S. Supreme Court case that held the federal Apology Resolution did not strip Hawaii of its authority to sell or transfer certain former crown lands, limiting the resolution’s legal effect.
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B.
Kelo v. City of New London
Kelo v. City of New London is a landmark 2005 U.S. Supreme Court case that expanded the interpretation of “public use” under the Takings Clause to allow government seizure of private property for economic development projects.
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C.
Federal Housing Administration v. Burr
Federal Housing Administration v. Burr is a landmark 1940 U.S. Supreme Court case that clarified the scope of federal sovereign immunity by holding that the FHA could be sued in certain circumstances under its "sue and be sued" clause.
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D.
Shelley v. Kraemer
Shelley v. Kraemer is a landmark 1948 U.S. Supreme Court case that held courts could not enforce racially restrictive housing covenants, marking a major civil rights victory against residential segregation.
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E.
Village of Arlington Heights v. Metropolitan Housing Development Corp.
Village of Arlington Heights v. Metropolitan Housing Development Corp. is a 1977 U.S. Supreme Court case that established the standard for proving discriminatory intent in equal protection challenges to facially neutral government actions, particularly in the context of zoning and housing discrimination.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Hawaii Housing Authority v. Midkiff Target entity description: Hawaii Housing Authority v. Midkiff is a 1984 U.S. Supreme Court case that broadly interpreted the Fifth Amendment’s Public Use Clause to allow government use of eminent domain for economic and social policy goals, such as breaking up concentrated land ownership.
-
A.
Hawaii v. Office of Hawaiian Affairs
Hawaii v. Office of Hawaiian Affairs is a 2009 U.S. Supreme Court case that held the federal Apology Resolution did not strip Hawaii of its authority to sell or transfer certain former crown lands, limiting the resolution’s legal effect.
-
B.
Kelo v. City of New London
Kelo v. City of New London is a landmark 2005 U.S. Supreme Court case that expanded the interpretation of “public use” under the Takings Clause to allow government seizure of private property for economic development projects.
-
C.
Federal Housing Administration v. Burr
Federal Housing Administration v. Burr is a landmark 1940 U.S. Supreme Court case that clarified the scope of federal sovereign immunity by holding that the FHA could be sued in certain circumstances under its "sue and be sued" clause.
-
D.
Shelley v. Kraemer
Shelley v. Kraemer is a landmark 1948 U.S. Supreme Court case that held courts could not enforce racially restrictive housing covenants, marking a major civil rights victory against residential segregation.
-
E.
Village of Arlington Heights v. Metropolitan Housing Development Corp.
Village of Arlington Heights v. Metropolitan Housing Development Corp. is a 1977 U.S. Supreme Court case that established the standard for proving discriminatory intent in equal protection challenges to facially neutral government actions, particularly in the context of zoning and housing discrimination.
- F. None of above. chosen
Statements (48)
| Predicate | Object |
|---|---|
| instanceOf |
Fifth Amendment case
ⓘ
U.S. Supreme Court case ⓘ constitutional law case ⓘ eminent domain case ⓘ |
| areaOfLaw |
eminent domain
ⓘ
property law ⓘ public use doctrine ⓘ |
| chiefJustice | Warren E. Burger ⓘ |
| citation |
104 S. Ct. 2321
ⓘ
467 U.S. 229 ⓘ 81 L. Ed. 2d 186 ⓘ |
| concurringJustices | all participating Justices joined the majority opinion without separate concurrences ⓘ |
| constitutionalBasisForTakingsClauseApplication | incorporation of the Fifth Amendment against the states through the Fourteenth Amendment ⓘ |
| constitutionalProvisionInterpreted |
Fifth Amendment to the U.S. Constitution
ⓘ
Fourteenth Amendment Due Process Clause ⓘ
linked to:
Due Process Clause
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1984-05-30 ⓘ |
| docketNumber | No. 83-141 ⓘ |
| factPattern | challenge to state program breaking up oligopolistic land ownership in Hawaii ⓘ |
| fullName |
Hawaii Housing Authority, et al. v. Midkiff, et al.
ⓘ
linked to:
Hawaii Housing Authority v. Midkiff
|
| geographicContext | land ownership concentration on the island of Oahu ⓘ |
| holding |
A taking is constitutional if it is rationally related to a conceivable public purpose.
ⓘ
Hawaii’s Land Reform Act did not violate the Public Use Clause. ⓘ The Public Use Clause of the Fifth Amendment is coterminous with the scope of a sovereign’s police powers. ⓘ The government may use eminent domain to transfer property from lessors to lessees to reduce concentrated land ownership. ⓘ |
| impact | expanded government authority to use eminent domain for economic and social policy goals ⓘ |
| jurisdiction |
State of Hawaii
ⓘ
linked to:
Hawaii
|
| keyPrinciple |
a taking is not invalid merely because property is transferred to private beneficiaries
ⓘ
courts will not substitute their judgment for that of the legislature on what constitutes a public use if the use is rationally related to a conceivable public purpose ⓘ |
| landmarkStatus | leading case on the meaning of public use in U.S. takings law ⓘ |
| legalIssue |
constitutionality of state land redistribution program
ⓘ
scope of the Fifth Amendment Public Use Clause ⓘ |
| nonParticipatingJustice | Justice Thurgood Marshall did not take part in the decision ⓘ |
| opinionAuthor |
Justice Sandra Day O’Connor
ⓘ
linked to:
Sandra Day O’Connor
|
| oralArgumentDate | 1984-01-11 ⓘ |
| originatingJurisdiction | United States Court of Appeals for the Ninth Circuit ⓘ |
| petitioner | Hawaii Housing Authority ⓘ |
| precedentFor | broad deference to legislative judgments about public use ⓘ |
| publicUseInterpretation | public use includes public purpose such as remedying social and economic evils ⓘ |
| relatedCase |
Berman v. Parker
ⓘ
Kelo v. City of New London ⓘ |
| remedySought | injunction against enforcement of Hawaii Land Reform Act condemnation provisions ⓘ |
| respondent | Frank E. Midkiff ⓘ |
| result | judgment of the Ninth Circuit reversed ⓘ |
| standardOfReview | rational basis review for public use determinations ⓘ |
| stateLawInvolved | Hawaii Land Reform Act of 1967 ⓘ |
| term | 1983 Term ⓘ |
| vote | 8-0 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Hawaii Housing Authority v. Midkiff Description of subject: Hawaii Housing Authority v. Midkiff is a 1984 U.S. Supreme Court case that broadly interpreted the Fifth Amendment’s Public Use Clause to allow government use of eminent domain for economic and social policy goals, such as breaking up concentrated land ownership.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
Hawaii Housing Authority v. Midkiff
→
fullName
→
Hawaii Housing Authority, et al. v. Midkiff, et al.
ⓘ
linked to: Hawaii Housing Authority v. Midkiff