The United States District Court for the District of Rhode Island has granted a preliminary injunction in the ongoing dispute over the Town of Coventry’s eminent domain taking of Johnson’s Pond, halting a parallel state court proceeding so that the property owners’ claims can be decided in federal court. KSPR Law obtained the ruling on behalf of the former owners of the Coventry reservoir.
In a Memorandum and Order issued March 12, 2026, Judge Melissa R. DuBose granted the owners’ motion for a preliminary injunction and denied the Town’s motion to dismiss or abstain. The order enjoins the Rhode Island Superior Court from proceeding with the scheduled adjudication of “just compensation” for the taking, preserving the federal court’s authority to decide that question.
The dispute
The Town of Coventry acquired Johnson’s Pond, a freshwater reservoir spanning roughly 938 acres, by eminent domain in 2024, depositing estimated compensation into the Superior Court registry to complete the taking. The owners do not contest the Town’s authority to take the property. The remaining issue is how much they are owed in just compensation under the Fifth and Fourteenth Amendments and Rhode Island law.
Relying on the Supreme Court’s decision in Knick v. Township of Scott (2019), the owners filed their federal claims first, in June 2025. Knick confirmed that a property owner may bring a federal takings claim the moment a taking occurs, without first litigating the question in state court. Weeks later, the Town asked the Superior Court to enter judgment on just compensation, raising the prospect that a state ruling could foreclose the owners’ federal claims under San Remo Hotel v. City and County of San Francisco (2005). That tension, often called the “San Remo trap,” put the owners at risk of losing their chosen federal forum before the federal court could act.
The ruling
The Court found that the owners’ federal claim ripened before the Town’s state court claim and that an injunction was warranted to protect the federal court’s jurisdiction. Drawing on the All Writs Act, Judge DuBose held that two recognized exceptions to the Anti-Injunction Act applied: the relief was expressly authorized under 42 U.S.C. § 1983, and it was necessary in aid of the Court’s jurisdiction.
The Court also rejected each of the abstention doctrines the Town raised, declining to step aside in favor of the state proceeding. Mindful of the limits on this kind of relief, the Court tailored its order narrowly, enjoining only the scheduled just compensation proceeding rather than the broader relief the owners had requested.
Why it matters
For Rhode Island property owners, the decision reinforces that the federal forum promised by Knick is meaningful, and that a federal court can act to prevent a parallel state proceeding from cutting off a property owner’s federal claims. For municipalities exercising the power of eminent domain, it is a reminder that the timing and forum of just compensation litigation can carry real consequences.
The matter is currently on appeal to the United States Court of Appeals for the First Circuit.
KSPR Law partners Michael A. Kelly and Scott D. Levesque, together with associate Gregory S. Estabrooks, represented the property owners. The full decision is available here (PDF).
