# Brown v. Legal Foundation of Washington *U.S. Supreme Court decision (2003) upholding IOLTA against a takings challenge* **Court and citation:** U.S. Supreme Court, 538 U.S. 216 (2003). Vote: 5–4.[^1] *Brown v. Legal Foundation of Washington* is a 2003 decision of the United States Supreme Court in one of the two takings cases over [[IOLTA]]. By a 5–4 vote, the Court upheld IOLTA.[^1] It ruled that the "just compensation" owed to each client is measured by the owner's loss. Because each client's interest is worth zero, that loss was nothing.[^2] The decision followed *[[Phillips v. Washington Legal Foundation]]*, 524 U.S. 156 (1998). In that case, also decided 5–4, the Court held that the interest is the client's property.[^1] Read together, the two rulings mean that the interest belongs to the client but that the compensation owed for it is zero.[^1][^2] ## Holding The Court upheld IOLTA by a 5–4 vote. On the question of just compensation, it measured compensation by the owner's loss and found that loss to be nothing, because each client's interest is worth zero.[^1][^2] ## Related decisions - *Phillips v. Washington Legal Foundation*, 524 U.S. 156 (1998): decided 5–4. The Court held that the interest is the client's property.[^1] - *Brown v. Legal Foundation of Washington*, 538 U.S. 216 (2003): decided 5–4. The Court upheld IOLTA and held that just compensation, measured by the owner's loss, is zero.[^1] ## See also - [[Washington Legal Foundation]] ## Notes [^1]: *The Instrument No One Will Name* (densified, 2026-06-18), note 66 — identifies the two IOLTA takings cases: *Phillips v. Washington Legal Foundation*, 524 U.S. 156 (1998), 5–4, holding that the interest is the client's property; and *Brown v. Legal Foundation of Washington*, 538 U.S. 216 (2003), 5–4, upholding IOLTA with just compensation equal to the owner's loss, which is zero. Marked primary-confirmed against the opinions on Justia. [^2]: *The Instrument No One Will Name* (densified, 2026-06-18), text at note 66 — states that the Supreme Court upheld IOLTA in *Brown* (2003, 5–4) because each client's interest is worth zero, with "just compensation" measured by the owner's loss. It also states that this ruling came after *Phillips* (1998, 5–4) held that the interest is the client's property.