Penn Central Transportation Company v. New York City: easy taking-clause cases make uncertain Law.

In Penn Central Transportation Company v. New York City, the Supreme Court held that New York City's Landmarks Preservation Law as applied to Grand Central Terminal was not a "taking" of property for which compensation is constitutionally required. The decision has been hailed as a major victory for landmark preservation, deplored as a threat to property rights, and praised for clarifying a confused area of legal doctrine. Little noticed is the fact that Penn Central did not pose the hard case for landmark preservation law: a case in which preservation imposes unique and severe economic burdens on a property owner. This comment argues that Penn Central was an "easy case"; the Court's doctrinal approach to the taking issue in Penn Central provides uncertain guidance for harder cases.