Local Government Law

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Essay
Volume 91.8
Post-Emption and the Mayoral Toolbox: Levers and Limits of City Resistance to State Preemption
Quinton D. Lucas
Mayor, Kansas City, Missouri.

Several individuals provided support and insight without which this Essay would not have been possible. Morgan Said’s administrative and political genius deserves credit for many of Kansas City’s successes, and this Essay is no exception. Others in the mayor’s office contributed time and critical thought, including Reid Day and Melesa Johnson. Nicholas Hine’s strategic assistance helped get this piece across the finish line, and Jack Wolverton’s diligent research assistance was fundamental in compiling data and references. Discussions with the exceptional students and faculty at the University of Kansas School of Law helped us refine our local government experiences for an academic context. Lastly, heartfelt thanks to the editors of the University of Chicago Law Review—particularly Aleena Tariq, Adrian Ivashkiv, and Helen Zhao—for their meticulous substantive and technical edits.

Gavriel Schreiber
General Counsel to the Mayor of Kansas City, Missouri.

Several individuals provided support and insight without which this Essay would not have been possible. Morgan Said’s administrative and political genius deserves credit for many of Kansas City’s successes, and this Essay is no exception. Others in the mayor’s office contributed time and critical thought, including Reid Day and Melesa Johnson. Nicholas Hine’s strategic assistance helped get this piece across the finish line, and Jack Wolverton’s diligent research assistance was fundamental in compiling data and references. Discussions with the exceptional students and faculty at the University of Kansas School of Law helped us refine our local government experiences for an academic context. Lastly, heartfelt thanks to the editors of the University of Chicago Law Review—particularly Aleena Tariq, Adrian Ivashkiv, and Helen Zhao—for their meticulous substantive and technical edits.

States increasingly deploy aggressive preemption measures against disfavored localities. Scholars have raised the alarm, but cities’ subordinate legal status leaves them disempowered. To push back, municipal advocates need to thoroughly understand the complex bilateral relationship between cities and their states.

That is where I come in. As Mayor of a progressive city in a conservative state, I swim in the hostile symbiosis that characterizes city-state relations. By drawing on real-life examples, closed-door conversations, and previously private documents, my coauthor and I demonstrate the potence of multi-pronged city power. We synthesize our stories into a thicker account of state motivation, and then showcase the city’s “toolbox” for limiting state preemption.

That process unearths preemption’s next frontier. Post-enactment state preemption, or “post-emption,” occurs when a state retroactively nullifies a specific, already-passed municipal law. It has been widely acknowledged but not individually distinguished. Analyzing it independently reveals that it is already ubiquitous and likely to proliferate. Post-emption thus warrants individualized normative assessment, and this Essay begins that surprisingly nuanced discussion.

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Comment
Volume 91.8
When the Taker Goes Broke: Takings Claims in Municipal Bankruptcy
Joshua Kayne Kaufman
B.A. 2021, The University of Chicago College; J.D. Candidate 2025, The University of Chicago Law School.

I would like to thank Josh Avratin, Douglas Baird, Vincent Buccola, Andrea Kayne, Kate Gehling, Ryan Schloessmann, Jenna Liu, Jack Brake, Karan Lala, and many other members of the University of Chicago Law Review for their thoughtful advice and feedback. In addition, I would like to thank Maria Sofia Peña, Andrea Kayne, Ariel Kaufman, Jacob Kaufman, Borscht Kaufman, Babka Kaufman, Justin Peña-Behar, and my friends for their support throughout the writing process. This Comment is dedicated to Chicago—my home for the past quarter century and a testament to the importance of giving communities a second chance.

When a municipality takes property, the former owners can allege a violation of the Takings Clause and try to recover just compensation. But what should happen when the municipality goes broke and enters municipal bankruptcy? Can the municipal bankruptcy code empower judges to release municipalities from their obligation to pay just compensation through a discharge? Or does the Takings Clause provide special constitutional protection to claims for just compensation from a municipality that immunizes the claims from discharge? This issue has played out in municipal bankruptcies in Detroit, Michigan; Stockton, California; and Puerto Rico—where courts are deeply divided on the right approach, resulting in a live circuit split. This Comment provides the first comprehensive analysis that shows takings claims are constitutionally dischargeable. As a threshold matter, the Comment shows that formalist considerations do not require immunizing takings claims from discharge. The Comment then shows that making takings claims dischargeable follows best from the original design of the Takings Clause given the host of procedural and political safeguards within municipal bankruptcy that would protect takings claimants against abuse. Lastly, the Comment shows that making takings claims dischargeable is normatively good.