Supreme Court of the United States
Brown v. Legal Foundation of Washington
March 26, 2003538 U.S. 216
Summary
The Supreme Court held that Washington's IOLTA program does not violate the Fifth Amendment's Just Compensation Clause. Even assuming the transfer of interest on client funds constitutes a taking, just compensation is zero because petitioners suffered no net pecuniary loss under state rules requiring non-IOLTA accounts whenever net interest could be earned. Justice Stevens delivered the opinion, and Justice Scalia dissented, arguing just compensation should be the fair market value of the interest taken.