Haw. Hous. Auth. v. Midkiff

467 U.S. 229, 104 S. Ct. 2321 (1984)



Federal courts should abstain from decision when difficult and unsettled questions of state law must be resolved before a substantial federal constitutional question can be decided. By abstaining in such cases, federal courts will avoid both unnecessary adjudication of federal questions and needless friction with state policies. Federal courts need not abstain on Pullman grounds when a state statute is not fairly subject to an interpretation which will render unnecessary adjudication of the federal constitutional question. Pullman abstention is limited to uncertain questions of state law because abstention from the exercise of federal jurisdiction is the exception, not the rule.


Appellant Hawaii Housing Authority ("HHA") enacted the Act after the Hawaiian legislature discovered only a small number of landholders owned the state's land. The legislature concluded that concentrated land ownership was responsible for skewing the state's residential fee simple market, inflating land prices, and injuring the public tranquility and welfare. The HHA held a public hearing concerning the acquisition of the landowner's property and made the statutory finding that the acquisition of the property effectuated a public purpose under the Act. The HHA then ordered the landowners to submit to compulsory arbitration, to which the landowners responded with the lawsuit. The United States Court of Appeals that the Act was unconstitutional. On appeal, the Court reversed judgment and remanded for further proceedings in conformity with the Court's opinion.


Is the Hawaii Land Reform Act providing for condemnation of residential tracts and resale to lessees constitutional?




The United States Court of Appeals for the Ninth Circuit held the Land Reform Act of 1967 (Act), Haw. Rev. Stat. § 516, unconstitutional in a suit brought by appellee landholders against appellant Hawaii Housing Authority (HHA).The Court found the Act constitutional by limiting the number of lots any one tenant could purchase and authorized the use public funds to ensure that the market dilution goals were achieved. The Court held that the HHA enacted the Act not to benefit a particular class of individuals but to attack certain perceived evils of concentrated property ownership in Hawaii, which was a legitimate public purpose, and that condemnation was not an irrational power to achieve that purpose.

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