Lingle v. Chevron U. S. A. Inc.

Summary

Justice O'Connor, writing for a unanimous Court, held that whether a regulation substantially advances legitimate state interests is not a valid regulatory-takings test. That inquiry concerns the regulation's underlying validity rather than the burden it imposes on property rights. Because Chevron relied exclusively on that theory to challenge Hawaii's service-station rent cap, the Court reversed the Ninth Circuit and remanded. The Court reaffirmed the established physical-taking, total-regulatory-taking, Penn Central, and land-use-exaction frameworks. Justice Kennedy concurred separately, without any other Justice joining, to emphasize that arbitrary or irrational regulation may still violate due process; Chevron's voluntarily dismissed due process claim was not before the Court.