The Four-Factor Penn Central Regulatory Takings Test

Steven J. Eagle

ABSTRACT

This Article examines the ad hoc, multifactor, regulatory takings doctrine derived from Penn Central Transportation Co. v. City of New York.  It analyzes the conventional three-factor characterization of the Penn Central factors, and concludes that a four-factor approach better captures the dynamics of the Penn Central analysis.  “Parcel as a whole,” conceptually regarded as delimiting the relevant parcel for the Penn Central inquiry, in fact interacts with the “economic impact,” “investment-backed expectations,” and “character of the regulation” factors.  While the four-factor analysis advocated here is conceptually better and enhances an understanding of how Penn Central operates, the doctrine remains under-theorized, subjective, with its factors mutually referential, and unable to provide a reliable guide to courts or litigants

PDF FULL TEXT

preferred citation:  Steven J. Eagle, The Four-Factor Penn Central Regulatory Takings Test, 118 Penn St. L. Rev. 601 (2014).