Lingle v. Chevron, U.S.A.
United States Supreme Court
544 U.S. 528 (2005)
In Hawaii, most gas stations are leased from oil companies by independent lessee-dealers, with the oil company owning the land and station and leasing it to the dealer. In 1997, Hawaii's legislature enacted a law restricting oil companies from converting existing lessee-dealer stations to company-owned stations, from locating company-operated stations near existing lessee-dealer stations, and capping the rent an oil company could charge a lessee-dealer. Chevron (plaintiff), Hawaii's largest gasoline marketer and supplier, sued the state's governor, Lingle (defendant), in federal court, alleging the rent cap constituted an uncompensated taking under the Fifth and Fourteenth Amendments; the district court granted Chevron summary judgment, holding the statute failed to "substantially advance" a legitimate state interest and thus effected an unconstitutional taking, and the court of appeals affirmed before the Supreme Court granted certiorari.
Whether the "substantially advances" formula articulated in Agins v. City of Tiburon, 447 U.S. 255 (1980), is a valid test for determining whether government regulation of private property effects a taking in violation of the Fifth Amendment.