The North Carolina Supreme Court ruled on Dec. 12, 2025, in a case that clarifies property owners' rights when government entities impose restrictions through corridor mapping under the state's eminent domain powers. The decision in Sanders v. North Carolina Department of Transportation addresses the intersection of due process requirements and just compensation protections under both federal and state constitutions.
William T. Sanders brought the case against the North Carolina Department of Transportation after the agency recorded corridor maps that covered portions of his property. The central legal question before the court was whether Sanders had abandoned his right to seek damages for Map Act restrictions by failing to raise the issue during NCDOT's subsequent condemnation proceedings.
The case reached the state's highest court through discretionary review of a unanimous, unpublished Court of Appeals decision from February 2024. The appeals court had affirmed a December 2021 order from Superior Court Judge Stephan R. Futrell in Cumberland County. The Supreme Court granted Sanders' conditional petition for discretionary review on an additional issue in March 2025, and heard oral arguments in September.
Justice Allen, writing for the court, opened the opinion by emphasizing the dual constitutional protections at stake: "Both the [United States] Constitution and the North Carolina Constitution require due process and just compensation when a public entity uses its eminent domain power to take property." The court cited its 2024 decision in Department of Transportation v. Bloomsbury Estates, LLC, which referenced both the Fourteenth Amendment and Article I, Section 19 of the North Carolina Constitution.
The case builds on the court's 2016 precedent in Kirby v. North Carolina Department of Transportation, where the justices held that restrictions imposed through corridor maps recorded under the Roadway Corridor Official Map Act constitute a taking by NCDOT. The Map Act allows transportation officials to designate future roadway corridors, potentially limiting property owners' development rights even before formal condemnation proceedings begin.
The procedural history reveals the complexity of modern eminent domain cases. NCDOT initially recorded corridor maps affecting Sanders' property, then later instituted formal condemnation proceedings. The question of whether Sanders waived his right to challenge the earlier mapping restrictions by not raising them during the condemnation case represents a common issue in transportation law, where property may be subject to multiple government actions over time.
Sanders was represented by attorneys from Cranfill Sumner LLP, including George B. Autry Jr., Stephanie H. Autry, and Jeremy H. Hopkins. The state's legal team included Attorney General Jeff Jackson's office, with Special Deputy Attorney General J. Aldean Webster III leading the defense alongside Howard B. Rhodes and Matthew W. Skidmore.
Notably, the case attracted amicus curiae participation from Beroth Oil Company and James & Carol Deans, represented by attorney Matthew H. Bryant. This third-party involvement suggests the decision's potential impact extends beyond the immediate parties, likely affecting other property owners facing similar corridor mapping situations.
The timing of the case reflects ongoing tensions between transportation infrastructure needs and property rights protections. As North Carolina continues expanding its highway system, corridor mapping has become an increasingly important tool for transportation planners. However, property owners have raised concerns about the impact of such designations on their ability to develop or sell their land.
The court's reference to constitutional due process requirements highlights the careful balance courts must strike in eminent domain cases. Property owners are entitled to fair procedures and just compensation when government entities exercise taking powers, but transportation agencies also need predictable legal frameworks for infrastructure development.
The Map Act itself represents North Carolina's attempt to streamline transportation planning by allowing advance designation of future roadway corridors. However, implementation of such forward-looking policies often generates litigation when property owners challenge the restrictions or seek compensation for diminished property values.
While the full text of the court's reasoning was not available, the case's procedural path through multiple court levels demonstrates the significant legal and practical issues at stake. The unanimous appeals court decision that was reviewed suggests some consensus among lower courts, though the Supreme Court's decision to grant review indicates important unresolved questions.
The decision comes at a time when eminent domain law continues evolving, particularly regarding regulatory takings and the timing of compensation claims. Property owners, transportation agencies, and legal practitioners will likely scrutinize the ruling for guidance on how corridor mapping restrictions interact with formal condemnation procedures.
For property owners facing similar situations, the case may clarify procedural requirements for preserving claims related to government mapping restrictions. Transportation agencies, meanwhile, may need to adjust their practices regarding corridor designation and subsequent condemnation procedures to ensure compliance with constitutional requirements.