The North Carolina Supreme Court ruled in *Mata v. N.C. Department of Transportation* on Dec. 12, 2025, addressing critical questions about just compensation for property takings under the state's now-repealed Transportation Corridor Official Map Act. The decision involves Elizabeth Mata and The Mata Family, LLC, who challenged restrictions placed on their property by the North Carolina Department of Transportation and North Carolina Turnpike Authority.
The case centers on approximately 9.93 acres of land owned by the Matas that became subject to corridor mapping restrictions on Aug. 6, 1996. The North Carolina Department of Transportation recorded a corridor map covering the property, which significantly restricted the owners' fundamental rights to improve, develop, and subdivide their land. These restrictions remained in place for nearly 20 years, creating substantial limitations on the property's use and development potential.
The Transportation Corridor Official Map Act, codified in N.C.G.S. sections 136-44.50 through 44.54, was designed to allow the state to preserve transportation corridors for future highway projects by restricting development along planned routes. However, the Act became controversial due to its impact on property owners' rights and the compensation mechanisms it provided.
The legal framework for this case changed dramatically in 2016 when the General Assembly rescinded all Map Act corridors on July 11, 2016. This action came in direct response to the North Carolina Supreme Court's decision in *Kirby v. North Carolina Department of Transportation*, 368 N.C. 847 (2016), which held that Map Act restrictions constituted a taking of property rights requiring just compensation.
The *Kirby* decision was a watershed moment in North Carolina property law, establishing that the Map Act's restrictions on property development constituted a compensable taking under both the North Carolina and federal constitutions. The ruling forced the state to confront the financial implications of the corridor mapping program, ultimately leading to the Act's repeal in 2019.
The *Mata* case proceeded through multiple levels of the state court system before reaching the Supreme Court. The litigation began in Wake County Superior Court, where Judge G. Bryan Collins, Jr. entered an order and judgment on June 5, 2023. The case then moved to the North Carolina Court of Appeals, which issued a divided decision reported at 294 N.C. App. 705 (2024), affirming in part and reversing in part the trial court's ruling and remanding for further proceedings.
The Court of Appeals' divided decision indicated disagreement among the appellate judges about the proper application of compensation standards under the repealed Map Act. This division likely contributed to the Supreme Court's decision to grant discretionary review under N.C.G.S. section 7A-31, allowing the high court to provide definitive guidance on these important property rights questions.
The Supreme Court heard oral arguments in the case on Sept. 16, 2025, before issuing its opinion in December. Justice Anita Earls authored the court's opinion, which the court characterized as addressing "two fundamental aspects of just compensation for takings effectuated under the now-repealed Transportation Corridor Official Map Act."
The case attracted significant legal representation on both sides. The Matas were represented by attorneys from Cranfill Sumner LLP, including George B. Autry, Jr., Stephanie H. Autry, and Jeremy P. Hopkins. The state defendants assembled a team including Howard B. Rhodes from The Banks Law Firm, P.A., Assistant Attorney General Jeanne Washburn from the North Carolina Department of Justice, William H. Moss from Smith, Anderson, Blount, Dorsett, Mitchell & Jernigan, LLP, and Matthew W. Skidmore from Skidmore Law Group, PLLC.
The *Mata* decision represents the latest chapter in North Carolina's ongoing effort to resolve compensation claims arising from the Map Act era. The Supreme Court's ruling provides crucial clarity for property owners and government entities dealing with the legacy of the corridor mapping program, establishing precedent for calculating just compensation in similar takings cases.
The decision has broader implications for eminent domain law in North Carolina, potentially affecting how courts evaluate compensation for temporary restrictions on property rights and long-term regulatory takings. Property rights advocates have closely watched the case as part of ongoing efforts to strengthen protections for landowners facing government restrictions on their property use.
While the Map Act has been repealed, numerous cases like *Mata* continue to work through the court system as property owners seek compensation for the restrictions they endured. The Supreme Court's clarification of compensation standards will likely influence the resolution of these pending cases and provide guidance for future property rights disputes involving government restrictions on land use.