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A long legal fight over land restrictions tied to a road project in North Carolina has reached a key point. The state Supreme Court has sent a Wake County landowner's compensation case back to trial judges so they can decide how much the property was worth.
Elizabeth Mata bought 94 acres of land in 1973. Decades later, state transportation officials set aside a 9.93-acre strip across her property for the planned Interstate 540 outer loop. The restriction limited her ability to build on or sell that part of the property for nearly 20 years. The North Carolina Supreme Court ruled that the restrictions imposed under the state's former Map Act amounted to an indefinite taking of property rights.
The justices sent the case back to a lower court to decide exactly how much money the North Carolina Department of Transportation (NCDOT) must pay Mata.
Decade-long restrictions on private property
The dispute began with the Transportation Corridor Official Map Act, a state law passed in 1987. The law allowed the NCDOT to file maps showing the planned routes of future highways. Once a map was filed with local officials, owners of property inside the marked area could not get building permits or develop their land.
State officials said the law was meant to control infrastructure costs. By stopping development in areas planned for future roads, the state could avoid higher costs later.
But the restrictions left thousands of acres across North Carolina in legal uncertainty for long periods, without the state officially buying the affected land. In Mata's case, state officials filed a corridor map in 1996 for an extension of the I-540 outer loop around Raleigh.
The planned highway route covered 9.93 acres of her 94-acre property. This effectively stopped development on that part of the land. The North Carolina General Assembly repealed the Map Act in 2019 after a series of legal defeats. The repeal came after a major 2016 ruling by the North Carolina Supreme Court in Kirby v. North Carolina Department of Transportation. That ruling found that corridor map filings were an unconstitutional taking of private property rights and required the state to provide just compensation under eminent domain rules.
Valuation disputes and legal arguments
Although lawmakers repealed the law, dozens of lawsuits were still open over how courts should calculate payments for owners affected by old corridor maps. During arguments before the North Carolina Supreme Court, attorneys for the NCDOT argued that the 2019 repeal changed the historical restrictions into temporary takings. The state's lawyers said damages should cover only the period when the corridor map was officially active.
Howard Rhodes, an attorney for the NCDOT, told the justices during oral arguments reported by the Carolina Journal that property owners affected by the Map Act should be fully compensated once. Rhodes argued that treating the restrictions as indefinite would require the department to pay much more than earlier legal decisions required. He said the state was trying to provide fair compensation under Supreme Court guidance.
Mata's lawyers argued that filing the corridor map created an indefinite restriction on her property rights. They said the restriction could not later be called temporary simply because lawmakers repealed the law. Her legal team said the state had effectively controlled the parcel for almost 20 years, greatly reducing its value and limiting how it could be used.
High court ruling and next steps
In its ruling, the North Carolina Supreme Court again found that corridor map filings created takings of indefinite duration, rather than short-term restrictions.
In its opinion, the justices said the state's original action permanently limited basic property rights from the date the map was recorded. The Supreme Court overturned lower court decisions that had used different methods to calculate compensation.
It ordered the trial court to reconsider the damages using established legal standards for indefinite takings. The ruling now allows a Wake County trial judge to hold hearings and determine the exact amount of money Mata should receive for the 9.93-acre section of her property. According to court filings in the North Carolina Judicial Branch docket system, the case will now return to Superior Court. Real estate appraisers and expert witnesses are expected to present evidence about the property's exact value and the financial effect of the state's long-running restrictions.

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