Pavlock v. Holcomb, No. 21-1599 (7th Cir. 2022)
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In 2018, the Indiana Supreme Court held that the state holds exclusive title to Lake Michigan and its shores up to the lake’s ordinary high-water mark. The plaintiffs, who own beachfront property on Lake Michigan’s Indiana shores, believed that their property extended to the low-water mark, and filed suit, alleging that the ruling amounted to a taking of their property in violation of the Fifth Amendment–a “judicial taking.” The defendants were Indiana officeholders in their official capacities: the Governor, the Attorney General, the Department of Natural Resources Director, and the State Land Office Director.
The Seventh Circuit affirmed the dismissal of the suit. None of the named officials caused the plaintiffs’ asserted injury or is capable of redressing it, so the plaintiffs lack Article III standing.
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