The Supreme Court ruling in this Hawaii property case almost entirely eliminated public use as a limit on the government taking private property in condemnation proceedings.
A Hawaii law, designed to lessen the power of oligopoly landowners, allowed lessees of single family homes to invoke eminent domain and buy the property they leased. The landowners challenged the law, saying that the condemnation was not for public use because the government immediately turned the land over to the former lessee. Justice Sandra Day O’Connor
Public use doctrine