Eminent Domain and City Redevelopment in California 101. Eminent Domain and City Redevelopment in California: An Overview and Case Study

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1 Eminent Domain and City Redevelopment in California 101 Eminent Domain and City Redevelopment in California: An Overview and Case Study Adalberto Aguirre, Jr., and Frances Vu liberty, and the pursuit of happiness are words that capture the essence of the American character. The framers of the U.S. Constitution Life, considered the pursuit of life, liberty, and happiness to be fundamental rights nested in the ownership of property, especially homeownership. For the Constitution s framers, the ownership of property was a vehicle for the material expression of life, liberty, and happiness. As a result, the framers of the Constitution regarded property as the foundation for freedom. Underscoring the importance of property, James Madison observed that, as a man is said to have a right to his property, he may be equally said to have a property in his rights (Cato Institute, 2005: 226). The Fifth Amendment to the Constitution enhanced the importance of property by protecting an individual s right to, and ownership of, property: No person shall be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation. Why did the framers of the U.S. Constitution place such an emphasis on property? Perhaps they were attempting to disguise a system of property rights that was already rooted in an unequal distribution of valued resources in society (Aguirre and Turner, 2007). James Madison argued in The Federalist 10 that the unequal distribution of property could result in competing factions that would threaten a representative democracy (Wright, 1961). In a document such as the Constitution, which outlines fundamental rights and freedoms, an emphasis on property rights would look forward rather than attempt to redress a history of unequal rights and freedoms in the population. In general, however, the framers of the Constitution promoted a common law principle regarding property: a distinction between individuals who own things and individuals who desire to own things owned by other individuals. As such, the framers were concerned with safeguarding an individual s right to own property and protecting that right from being taken away by another individual. Adalberto Aguirre, Jr., is Professor and Chair in the Department of Sociology at the University of California Riverside ( adalberto.aguirre@ucr.edu). His research interests are in the areas of critical race theory, educational leadership, and race/ethnic relations. Frances Vu is a graduate student in the Department of Sociology at the University of California Riverside ( frances.vu@gmail. com). Her research interests are in the areas of critical race theory and race/class inequality. Social Justice Vol. 33, No. 3 (2006) 101

2 102 Aguirre, Jr., and Vu Despite such efforts to protect property rights, the expansion of regulatory authority by government at all levels city, county, state, and federal has attacked the framers intent to protect property ownership. The expansion of regulatory authority has allowed government to increase the taking of property through measures such as eminent domain (Cramer, 2004). This article will discuss the government s use of eminent domain to seize property from owners, especially homeowners. Specifically, we examine the general use of eminent domain strategies by cities and counties to take property from homeowners to benefit private commercial interests, rather than public interests. We begin with a brief overview of the notion of eminent domain and then discuss Kelo v. City of New London (125 S. Ct [2005]) regarding the use of eminent domain to circumvent homeowner property rights. A case study follows of how homeowners in Riverside County, California, responded to the taking of their property by local government agencies. Eminent Domain as Public Power The framers of the Constitution designed to protect property rights within reasonable limits. Although they recognized the importance of protecting property rights, they also recognized the need for government to provide for the public good or benefit. One of the reasonable limits imposed on property ownership, as set forth in the Fifth Amendment, allows government to take property for public use upon payment of just compensation. This principle is recognized as the government s power of eminent domain. Though eminent domain is not specifically listed in the Constitution as a power of government, it is implicit in the just compensation clause of the Fifth Amendment. As such, eminent domain is an instrumental power that allows government to act under some other power to pursue the public interest, such as building roads or preserving wildlife habitats. According to Klemetsrud (1999: 783), The Fifth Amendment to the United States Constitution grants federal and state governments the authority to take private property for a public use provided just compensation is paid. Courts in the United States have long understood the Fifth Amendment to mean that a governmental taking must satisfy a public use in order to constitute a legitimate exercise of eminent domain. Traditionally, this power commonly referred to as eminent domain had come to mean the taking of property only when it was actually used by the public. Such uses were limited to public parks, roads, sewer systems, hospitals, and other similar developments to which the public had actual physical access. The term eminent domain originated in 1625, when Hugo Grotius wrote in De Jure Belli et Pacis that the property of subjects is under the eminent domain of the state, so that the state or he who acts for it may use and even alienate and destroy

3 Eminent Domain and City Redevelopment in California 103 such property...in which even private persons have a right over the property of others, but for the ends of public utility... (Ibid.). Grotius also noted in De Jure Belli et Pacis that the taking of private property also required compensation to the loser of property: a king can take away from his subjects [property] by the power of eminent domain. In order to do it by the power of eminent domain, first, the public welfare must require it, and second, compensation must be made to the loser, if possible, from the public funds (quoted in Sandefur, 2003: 571). Grotius thus identified the two basic requirements for the taking of private property that are reflected in the Fifth Amendment: public use limitation and compensation. Kelo v. New London On June 23, 2005, the U.S. Supreme Court reaffirmed in Kelo v. New London [125 S. Ct (2005)] a governmental agency s use of eminent domain to condemn private property for public use. In Kelo, the New London Development Corporation (NLDC) sought the condemnation of 15 homes in the Fort Trumbull neighborhood of New London, Connecticut. In 1990, the state of Connecticut designated New London as a distressed municipality, and in an effort to revitalize New London, state and local officials formed the NLDC to assist the city with redevelopment plans and projects. In January 2000, the New London city council approved the redevelopment plan submitted by the NLDC and authorized NLDC to acquire private property by exercising the power of eminent domain in the city s name. The redevelopment plan submitted by the NLDC focused on revitalizing the distressed city through increased tax revenues and job creation. In particular, NLDC s redevelopment plan was motivated by the Pfizer Corporation s announcement in February 1998 that it would build a $300 million facility in the Fort Turnbull area of New London. To implement the plan, the city set out to buy land from willing sellers and to use the power of eminent domain to obtain land from the unwilling ones. Specifically, New London intended to acquire land in seven parcels: parcel one for a waterfront hotel and conference center, parcel two for eighty new residences as part of a new urban neighborhood, parcel three for research and development office space for either Pfizer or other new businesses, parcel four that would support either the park or the marina, and, parcels five, six, and seven for additional office and retail space, parking and waterdependent commercial uses (Jones, 2005: 143). In December 2000, Suzette Kelo, along with others whose property fell within the parcels listed in the redevelopment plan, filed suit in the Superior Court of Connecticut claiming that the promise of a public benefit that would result from higher taxes and more jobs did not meet the public use limitation outlined in the Fifth Amendment. The petitioners in Kelo argued that the public use limitation in

4 104 Aguirre, Jr., and Vu the Fifth Amendment protected them from the taking of private property from homeowners for the benefit of a private commercial interest, the Pfizer Corporation. The petitioners in Kelo owned 15 properties (family homes) in the Fort Turnbull area: four in parcel three and 11 in parcel four of the redevelopment plan. The Superior Court issued a restraining order regarding the properties located in parcel four (park or marina support), but not for the properties located in parcel three (office space). The parties in Kelo appealed to the Connecticut Supreme Court. The court upheld the Superior Court s ruling regarding the properties in parcel three, but reversed the ruling regarding the properties in parcel four. The Connecticut Supreme Court argued that the NLDC had offered a redevelopment plan in which the Pfizer Corporation planned to restore land for parks, create jobs, and promote residential living areas. As such, the court reasoned that the redevelopment plan met the public use interest and, as a result, justified the use of eminent domain by the NLDC. In what is often referred to as the most important property rights case of the last half century, the U.S. Supreme Court heard oral arguments in Kelo v. New London on February 22, On June 23, 2005, it entered its decision that the city of New London had developed a redevelopment plan that would provide appreciable benefits to the community via job creation and increased tax revenue. The Court upheld the Connecticut statute giving the city of New London the power of eminent domain to promote economic development, ruling that: given the plan s comprehensive character, the thorough deliberation that preceded its adoption, and the limited scope of this Court s review in such cases, it is appropriate here to resolve the challenges of the individual owners, not on a piecemeal basis, but rather in light of the entire plan. Because that plan unquestionably serves a public purpose, the takings challenged here satisfy the Fifth Amendment [125 S. Ct (2005), at 2665]. Regarding whether a promised public benefit satisfies the Fifth Amendment s public use requirement, in writing for the majority Justice Stevens noted that, promoting economic development is a traditional and long accepted governmental function, and there is no principled way of distinguishing it from other public purposes the Court has recognized [125 S. Ct (2005), at 2665]. In a dissenting minority opinion written by Justice O Connor, and joined by Chief Justice Rehnquist and Justices Scalia and Thomas, she warned that, under the banner of economic development, all private property is now vulnerable to being taken and transferred to another private owner, so long as it might be upgraded i.e., given to an owner who will use it in a way that the legislature deems more beneficial to the public in the process (quoted in Jones, 2005: ). The Justices were issuing a warning to the nation s homeowners that governmental agencies would argue that the conversion of private (e.g., residential) property into redeveloped

5 Eminent Domain and City Redevelopment in California 105 (e.g., commercial) property will always result in greater economic benefits for the public, thus meeting the public use limitation listed in the Fifth Amendment. The decision in Kelo placed the public interest at risk from private commercial development interests that treat the public as an exploitable market. Unsurprisingly, the Supreme Court s decision in Kelo sparked controversy at all levels of government and public life. State legislatures in Texas, California, and Indiana called for constitutional amendments that would shore up private property rights (Browning, 2005). A representative in the Missouri legislature proposed a bill requiring that beyond getting fair market value for their homes, displaced homeowners would receive two percent of the gross revenues of the new development for 20 years (Kingsley, 2006). Legislation was approved in the Illinois Senate that would prohibit the taking of property for private development unless the targeted area was blighted. The legislation also required that property values be determined 180 days before the start of a condemnation trial if the trail took place more than one year after the start of condemnation proceedings (Mackey, 2006). The Institute for Justice, a nonprofit, Washington-based group, launched a nationwide campaign, Hands Off My Home, to educate citizens about strategies they could use to protect their homes from government-forced takings for private development (Kingsley, 2005). Similarly, a Minnesota group of concerned citizens and elected officials formed an organization, Minnesotans for Eminent Domain Reform (MNEDR), to lobby state legislators to pass laws preventing eminent domain abuse (Jones, 2006). In general, the public s response to Kelo identified two potential problems for homeowners regarding the Fifth Amendment s takings clause. Kelo was clear about the takings clause and public use interest: local governments had broad powers to use eminent domain to seize people s homes and resell the properties to private businesses that promised to create jobs and increase tax revenues. A potential problem for homeowners nested in the Supreme Court s reasoning in Kelo is that economic stability is identified as public use. Following the standard established in Kelo, private parties proposing a redevelopment plan before a city council, such as to build a shopping center, can argue that their plan will result in greater economic benefits to local government (e.g., higher property and sales taxes) than residential property provides. As a result, private parties with deeper economic pockets, who can offer the promise of economic benefits, will have more influence over local governments than do residents, and will influence local governments to use eminent domain to implement their development plans. A second potential problem for homeowners in Kelo concerns the conversion of residential property into commercial property. A crucial assumption in redevelopment plans is that greater economic benefits are derived from the conversion of residential property into commercial property because commercial property carries a higher level of valuation. An unfavorable outcome for homeowners is that they may not receive true market value for their property because it is appraised at the

6 106 Aguirre, Jr., and Vu residential instead of the commercial rate. Is the just compensation clause in the Fifth Amendment met by offering homeowners compensation at prevailing rates for residential property valuation or by offering compensation based on the rates for commercial property valuation? It might be more equitable for homeowners and for meeting the just compensation clause if their properties were bought by local government at the valuation rate set for commercial property or their promised appraised value as commercial property. Not to do so transforms eminent domain into a strategy for preventing homeowners from receiving just compensation and for subsidizing private commercial development interests. Property Interests in California California is home to some of the priciest real estate in the United States. The high price of real estate in California has made it one of the most active states in the use of eminent domain to promote private development interests. According to a 2003 study by The Institute for Justice, between 1998 and 2002 there were almost 1,000 cases in which local governments in California used or threatened the use of eminent domain to take property (Stokley, 2004). For local governments interested in developing areas commercially, especially residential areas they identify as blighted, eminent domain is an important tool for taking land away from property owners. Though it is beyond the scope of this article to examine the extent to which local governments use eminent domain in promoting redevelopment projects, one can at least observe the situations in which local governments use eminent domain to take property. For example, consider the following instances in which California local governments have used eminent domain proceedings to obtain land for private development. (An extensive nationwide summary of communities experiencing eminent domain takings can be found at Alhambra: The city declared 60 businesses blighted, including the Museum of Contemporary Arab Art, to redevelop the area into upscale condominiums and shops. California City: City officials declared over 700 acres of Mojave Desert land owned by 246 owners to be urbanized and blighted as a first step in the condemnation process. The city built a Hyundai/Kia auto test track on the condemned property. Lemon Grove: City officials asked business and residential property owners in a seven-acre strip near the city s northern entrance if they would be interested in participating in a proposed redevelopment plan for the area. The plan proposed to build new homes and office space. Though the city said it would not use eminent domain to take property, one homeowner received a written offer from a developer who told her the city would condemn her property if she refused to sell. Monterey Park: Acting as the city s redevelopment agency, the

7 Eminent Domain and City Redevelopment in California 107 city council proposed the use of eminent domain to condemn three commercial buildings to make way for Atlantic Times Square. The move would displace several family businesses and replace them with luxury condominiums, retail shops, and a movie theater. National City: Mossy Nissan leased its four and one-half acre block in the famed Mile of Cars auto park. The auto dealer wanted to purchase the land and expand. While negotiating a purchase price with the landowner, the auto dealer went to the city and threatened to leave unless it condemned the property for them. The city did so. At the last minute, the property owner reached an agreement with the auto dealer to avoid condemnation. Riverside: In July 2005, the city council brought in Thrifty Oil Company to build a four-story medical building with restaurants and retail establishments in the downtown area. However, neither the city nor Thrifty owned the land for the proposed commercial project. The property owner had already started construction on an office building. Citing the need for commercial development in the downtown area as justification for acquiring the land, city officials proposed taking the land from the owner by eminent domain and handing it over to Thrifty. San Bernardino: The city council voted to reinstate the power of eminent domain over 433 acres of homes in the Uptown and Central City neighborhoods for possible future private commercial development. San Diego: The San Diego Model School Development Agency was created to promote the development around a new school planned in City Heights. Beyond the 120 homes that were demolished to make way for the school, the agency has now proposed acquiring through eminent domain 188 more homes on the surrounding 30 acres to build new apartments, condominiums, and town homes. Vasalia: City officials used eminent domain to take ownership of a downtown theater. However, the building was in escrow to be sold to Restoration Inc., a north Visalia church. The city decided the theater should be used as a playhouse instead of a church and condemned the property to get its way. In November 2005, a judge ruled that the city s use of eminent domain was legal, calling the arts a public use, even though a deal had already been reached by the property owner and the church. One warning in Justice O Connor s minority opinion for Kelo was that local governments might extend their use of eminent domain to promote private development. Following Kelo, local governments can use the promise of job creation and increased tax receipts to meet a public use interest. As the preceding examples

8 108 Aguirre, Jr., and Vu show, local governments clearly use eminent domain as a tool to promote private development at the expense of homeowners. The interpretation of the public use clause in the Fifth Amendment has been truncated to mean that private development is public use if there is a promise of benefits to the public as perceived by local governments acting as the public s agent. The operating assumption is that local governments will always act in the public s best interest. Riverside City Redevelopment The city of Riverside is the county seat of Riverside County, California. According to the 2000 U.S. census, the city s population totaled 255,166. A 2004 U.S. census population report identified Riverside County as the fastest growing county in the state; the city of Riverside was the largest city in the Inland Empire Region, and the 12th largest municipality in the state of California (Miller, 2005). Much of the population growth experienced by the city of Riverside is due to the movement of people from surrounding counties (e.g., Orange and Los Angeles counties), who are seeking affordable housing. One outcome of the growing population has been the expansion of residential housing projects and the building of retail and business centers. To meet the business and retail needs of a rapidly growing population, the city of Riverside actively began taking property via eminent domain to promote redevelopment projects well before the Kelo decision. The Riverside city council acts as the Riverside Redevelopment Agency (RDA) to promote such projects. Besides using eminent domain to take land, the RDA has played a noticeable role aiding the city in the removal of the homeless population from the downtown areas, thereby increasing their attractiveness to private developers (Aguirre and Brooks, 2001). Acting under the authority of the RDA, for example, the city promoted the development of the University Village commercial center. The project was a centerpiece of the city s interest, as well as that of the University of California, Riverside, in developing a commercial center that would offer retail and entertainment services to students attending the university. According to the mayor of Riverside, the University Village would provide students with a place to go and feel comfortable (Danelski, 1996c: B1). To make the project work, the RDA had to acquire the land from property owners before selling it to private developers. Since the property owners were unwilling to sell their land to the city, the RDA used eminent domain to seize it. Some of the most noticeable aspects of the redevelopment project were the following (Danelski, 1995; 1996a, b, c; Pascual, 1996): When the owner of a parcel leased to a gas station refused the city s offer of $635,000, the city threatened to use eminent domain to seize the land. The landowner eventually accepted the RDA s offer. The RDA then sold the parcel to the private developer for $225,000. In an effort to help the city attract a private developer, the University of

9 Eminent Domain and City Redevelopment in California 109 California Board of Regents approved the Riverside campus spending of one million dollars for the University Village project. That sum would allow the university to rent classroom space (e.g., three screens) in the 10- screen movie theater at the University Village. The university maintains an ongoing agreement with the University Village to rent some of the screens for classroom use. The owner of a car dealership refused the RDA s offer of $1.8 million for the property. The owner argued that both the city and county had appraised the property at $2.9 million. The RDA used the power of eminent domain to seize the property. The owner sued the RDA in Superior Court. The Superior Court gave the RDA authority to seize the owner s seven-acre parcel. In summary, to develop the 14-acre University Village center, the RDA either bought or seized property through eminent domain that had been occupied by a gas station, an auto dealership, two restaurants, and a motel. A Neighborhood Responds The University Village project serves as an example of how local governments can promote private development through the use of eminent domain. This project was also a catalyst for other redevelopment projects in areas the city had designated as blighted, much like what happened in New London, Connecticut. In October 2003, the Riverside City Council, on a six to zero vote, approved a redevelopment project in two areas on the city s west side, Arlanza and La Sierra. The city council also approved a project area committee consisting of five council members, because state law requires such a committee if the areas involved contain a substantial number of low-income homeowners and the city intends to use eminent domain to acquire residential property (Haberman, 2003). The city s redevelopment agency projected that the Arlanza and La Sierra project would generate $447 million in new taxes and $201 million for building affordable housing throughout the city of Riverside. The new taxes would result from the increase in property value in the redevelopment area due to inflation, reinvestment, and property improvements. The $201 million earmarked for affordable housing had one implication for low-income homeowners in the Arlanza and La Sierra areas: the redevelopment project was going to displace them. Displacing low-income homeowners from Arlanza and La Sierra may have been an implicit expectation for the redevelopment project. Almost a year later, in August 2004, a group of homeowners in the Arlanza and La Sierra areas, calling themselves Rural Residents and Horse Owners of Riverside (RHR), filed suit in Superior Court to halt the redevelopment project. The homeowners argued that the city was ignoring that much of the affected areas was zoned for rural residential and animal keeping. According to the homeowners,

10 110 Aguirre, Jr., and Vu it s redevelopment. It s another layer of government that allows them to take our property and give it to a developer, and we have to fight for the so-called fair-market value (Trone, 2004: B1). Ironically, the group of homeowners was more interested in preserving a rural lifestyle and horse trails than in protecting the property rights of low-income residents. In February 2005, the city of Riverside petitioned the Superior Court to dismiss the suit filed by the RHR. The judge rejected the city s petition. Next, the city petitioned the State Court of Appeals to review the lower court s ruling. On April 7, 2005, the appeals court denied the city s petition. Rather than continue to fight in the courts, the city decided to pursue an agreement with the RHR. In a strange twist, the County of Riverside sided with the RHR to remove itself as a defendant in the lawsuit. The agreement reached between the city, county, and RHR would remove two square miles from the redevelopment project, which would reduce new taxes by $49 million and generate $22 million less for affordable housing (Haberman, 2005b). The land that would be cut from the redevelopment project is a vacant parcel known as Rancho La Sierra. Interestingly, the homeowners residing in the parcel are interested in developing it to accommodate 600 luxury homes. In a noteworthy development, in October 2005 a group calling itself Riversiders for Property Rights launched a petition drive to gather 17,000 signatures to call for a special election. The only measure appearing on the ballot proposed to outlaw the use of eminent domain by the city to acquire property in order to transfer it to a private developer (Haberman, 2005a). The city of Riverside filed suit in Superior Court to stop the group from gathering signatures. The city argued in its petition to the court that eminent domain was not a permissible subject for a local initiative; it was only permissible for a statewide initiative. Riversiders for Property Rights argued that the city s lawsuit was a repression of residents First Amendment rights and an infringement of their voting rights. On March 10, 2006, the Superior Court judge dismissed the city s lawsuit (Haberman, 2006). Because the group was defending itself against the city, it was unable to meet the deadline for gathering the necessary signatures. However, it vowed to continue gathering signatures to call for a special election at a later date. Summary Comments The minority opinion written in Kelo by Justice O Connor warns that all property is now at risk of being taken over by government to promote private development interests. Kelo does indeed open the door for private developers to entice local governments with the promise of creating jobs and increased tax receipts. What local government would not find such an offer attractive? Yet who bears the cost of fulfilling this promise? The framers of the Constitution sought to protect the property owner from loss; they intended for property owners to receive just compensation for their property rights. Well before the U.S. Supreme Court s decision in Kelo, local governments in

11 Eminent Domain and City Redevelopment in California 111 California were using eminent domain to take property for private development. An example of a redevelopment agency s use of eminent domain is the University Village project. The Riverside Redevelopment Agency argued that the project would generate economic benefits for the city, as well as provide entertainment and retail venues for students attending the University of California at Riverside (adjacent to the University Village). The decision of the University of California Regents to commit public funds to the project was instrumental in attracting private developers to the project. So, who benefits? Are university students the primary beneficiaries of the University Village project? How do city residents benefit, especially when the project is designed to attract and serve university students? A contrasting approach is seen in the city of Riverside s decision to pursue redevelopment projects on its west side. The area targeted by the city consisted primarily of low-income residents, creating suspicion that the city was using eminent domain to displace low-income residents and thus enhance the area s appeal to private developers. Interestingly, the homeowners challenging the city s redevelopment project, Rural Residents and Horse Owners of Riverside, were mostly concerned with protecting their own property, not that of low-income residents. By removing it from the redevelopment project, they sought to pursue their own development plans for high-end luxury homes. Here, displacement of low-income residents increases the chances for the city to attract private developers and for the RHR to attract homebuyers to its high-end luxury homes. The cost of redevelopment is borne by the low-income residents displaced from the redevelopment area. The framers of the Constitution did not foresee a future in which public use would be truncated to mean anything that benefits private interests. The framers were not able to conceive of the emergence of neoliberal policies that would promote privatization in order to secure market interests. The framers did not suspect that government would play an important part in promoting private commercial development at the expense of individual property rights. As much as they sought to protect property rights, the framers did not envision the possibility that property could be used as a tool in the economic exchange relations between citizens and government an exchange relationship in which citizens do not possess the capital to compete with private development. Kelo is a warning to all property owners that the right to property is nested in government s ability to determine who benefits from the use of property. As a result, property ownership is no longer a guarantee that one is protected from incursion from outside parties, especially private developers acting under the auspices of government. The Kelo decision may have tarnished those key words used to describe the American character and spirit life, liberty, and the pursuit of happiness.

12 112 Aguirre, Jr., and Vu REFERENCES 1996c Aguirre, Jr., A. and J. Turner 2007 American Ethnicity: The Dynamics and Consequences of Discrimination. Fifth edition. New York: McGraw-Hill. Aguirre, Jr., A. and J. Brooks 2001 City Redevelopment Projects and the Criminalization of the Homelessness: A Narrative Case Study. K.F. Gotham (ed.), Critical Perspectives on Urban Redevelopment. New York: Elsevier: Browning, R Eminent Domain: Eminent Domain Under Fire Following Supreme Court Ruling. The Indiana Lawyer (August 10): 1. Cato Institute 2005 Cato Handbook on Policy. Washington, D.C.: Cato Institute. Cramer, B Eminent Domain for Private Development An Irrational Basis for the Erosion of Property Rights. Case Western Reserve Law Review 55: Danelski, D. 1996a City Ready to Sue to Get Last Piece of Village Project. Press Enterprise (Riverside, CA, January 3): B b Riverside Agency Gets Approval to Take 7 Acres for University Village Project. Press Enterprise (Riverside, CA, January 4): B1. Agency Targets Gas Station, Wants Way Clear to Center. Press Enterprise (Riverside, CA, March 6): B UCR Could Get a Ticket to Movies for $1 Million. Press Enterprise (Riverside, CA, June 8): B1. Haberman, D Judge Dismisses Initiative Suit. Press Enterprise (Riverside, CA, March 11): B a Petition to Target Eminent Domain. Press Enterprise (Riverside, CA, October 25): B2a. 2005b Residents Get Early Victory. Press Enterprise (Riverside, CA, April 30): B Council Backs Blight Help for Two Districts. Press Enterprise (Riverside, CA, October 8): B1. Jones, B Eminent Domain Initiative Launched in Minnesota. The Minnesota Lawyer (January 9): 1. Jones, S That Land Is Your Land, This Land Is My Land Until the Local Government Can Turn It for Profit: A Critical Analysis of Kelo v. City of New London. BYU Journal of Public Law 20: Kingsley, C Eminent Domain Bills Take Center Stage in Missouri Legislature. Kansas City Daily Record (February 21): B Hands Off My Home Campaign Addresses Eminent Domain Case. Kansas City Daily Record (July 18): B1. Klemetsrud, J The Use of Eminent Domain for Economic Development. North Dakota Law Review 75: Mackey, B Bill Would Raise Bar on Taking Land. Chicago Daily Law Bulletin (February 16): 1. Miller, J Inland Area Growing Fast. Press Enterprise (Riverside, CA, February 8): B1.

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