SIGNIFICANT CASE SUMMARY

Maryland Significant Case Summary

Poppleton Now Community Association, Inc. V. LA Cite Development, LLC
Fourth Circuit Court of Appeals
No. 25-1770

Decided: May 4, 2026

Fourth Circuit declines to exercise supplemental jurisdiction and “kicks the case to state court” when no other basis for jurisdiction over state law claims exists.

Background

Beginning in 2004, Baltimore City initiated a process to redevelop 13.8 acres of land in the Poppleton neighborhood. The City reached an agreement with a developer in late 2006 to begin the project. The 13.8 acres included a number of existing city blocks, including over 500 individual homes. The City acquired those homes through, among other things, eminent domain. Nearly 20 years after the development contract was reached, in 2024, only one apartment building had been completed. As a result, six City residents and one community organization filed suit against the City, the developer, and a number of other defendants. None of the Plaintiffs had property located within the 13.8 acres, thus they had no property taken. Nonetheless, the Complaint was filed in federal court under the Federal Question doctrine (28 U.S.C. § 1331) alleging violation of the Taking clause under the Fifth Amendment, because their neighbors’ property was acquired through eminent domain but was not taken for public use. Plaintiffs also included a state law question, claiming that the blighted condition of the still vacant land in the redevelopment project area amounts to a private nuisance under Maryland law.

The district court dismissed Plaintiffs’ federal law claim for lack of standing, holding that because none of their property was taken, no injury occurred. In a refusal to exercise supplemental jurisdiction, the district court also dismissed the state law claim, holding that Plaintiffs failed to state a private nuisance claim under Maryland law. Plaintiffs appealed to the Fourth Circuit Court of Appeals.

Holding

Regarding Plaintiffs’ private nuisance claim, Fourth Circuit held that the district court erred in reaching the merits of the Plaintiffs’ private nuisance claim when it skipped analyzing supplemental jurisdiction. Plaintiffs’ private nuisance claim is one made under Maryland Law. In dismissing Plaintiffs’ federal law claims, no other basis for federal jurisdiction over the state law private nuisance claim existed. At that point, the Fourth Circuit held that the district court should have analyzed whether to exercise supplemental jurisdiction before reaching the merits of the private nuisance claim. The Fourth Circuit reaffirmed a longstanding general rule in holding that when a district court dismisses all federal claims in early states of litigation, it should decline to exercise supplemental jurisdiction over remaining state law claims. This meant that the district court should have “kick[ed] the case to state court,” instead of reaching the merits of the state law claims.

Questions about this case can be directed to Alex Mitchell at (443) 641-0563, or amitchell@tthlaw.com.