The Town of Lockport Industrial Development Agency (LIDA) authorized the condemnation of 91 acres of vacant land owned by GM Components Holdings, LLC to facilitate the expansion of the Industrial Park. GM filed suit to challenge the decision. On review, the court examined (1) the authority by which LIDA acted, (2) whether the acquisition serves a public use, (3) if the decision was constitutionally sound, (4) if the decision complied with SEQRA and EDPL Article 2. As is required for such cases, the burden lays with the party challenging the condemnation to show the determination was baseless. They failed to do so.

In justifying its actions, LIDA cited an array of statistics about the Industrial Park, including the number of businesses operating therein, nearly $400 million in investment, and the roughly 500 local residents employed at companies in the Industrial Park. Based on this evidence, the court found the use of eminent domain to be “rationally related to a conceivable public purpose,” and further ruled it had complied with the statutory procedures, including the required environmental reviews. Thus the decision was upheld by the Court.

The case was GM Components Holdings, LLC v. Town of Lockport Indus. Dev. Agency, 977 N.Y.S.2d 836 (N.Y. App. Div. 4th Dept. 2013); appeal dismissed, 22 N.Y.3d 1165 (2014)