---
title: "Shoemaker v. United States — AP Lang Evidence Guide"
description: "Shoemaker v. United States (1893) upheld eminent domain for Rock Creek Park. Use it as historical evidence in AP Lang arguments about government power and public good."
canonical: "https://fiveable.me/ap-lang/key-terms/shoemaker-v-united-states"
type: "key-term"
subject: "AP English Language"
---

# Shoemaker v. United States — AP Lang Evidence Guide

## Definition

Shoemaker v. United States (1893) is the Supreme Court case that affirmed Congress's power to use eminent domain to acquire land for public parks, specifically Rock Creek Park in Washington, D.C. In AP Lang, it works as concrete historical evidence in arguments about government power and the public good.

## What It Is

Shoemaker v. United States is an 1893 Supreme Court decision holding that Congress can use [eminent domain](/ap-lang/key-terms/eminent-domain "fv-autolink") (the government's Fifth Amendment power to take private property for public use, with just compensation) to acquire land for a public park. The land in question became Rock Creek Park in Washington, D.C., one of the country's first major urban parks. The Court's logic was that a park counts as a legitimate "public use," even though nobody drives on it or drinks from it the way they would a road or a reservoir.

For [AP Lang](/ap-lang "fv-autolink"), you're not studying this case the way an AP Gov student would. It lives in Topic 11.2 because it's exactly the kind of specific, verifiable [evidence](/ap-lang/unit-2/developing-thesis-statements/study-guide/3KvISz4DdXOOKPTU4qbd "fv-autolink") that turns a vague argument essay into a strong one. If your prompt touches on government authority, public spaces, the tension between individual property rights and collective benefit, or how societies define "the public good," Shoemaker gives you a named case, a date, and a concrete outcome to build commentary around.

## Why It Matters

This term maps to Topic 11.2, [Building Strong Evidence and Commentary for the Argument Essay](/ap-lang/argument-essay/evidence-commentary/study-guide/wE6wK6rdYreIG3vJ "fv-autolink"). The argument FRQ (Question 3) asks you to take a position and defend it with evidence from your reading, knowledge, or experience. Graders consistently reward specific, accurate evidence over generic claims like "the government sometimes takes land." Shoemaker lets you say something precise instead, that in 1893 the Supreme Court ruled the federal government could seize private land to create Rock Creek Park because public recreation qualifies as public use. The real payoff, though, is the commentary you attach to it. The case forces a genuinely arguable question into view, which is what counts as a benefit big enough to justify taking someone's property. That tension is fuel for nuanced argumentation, the kind that earns the [sophistication point](/ap-lang/key-terms/sophistication-point "fv-autolink").

## Connections

### Eminent domain (Topic 11.2)

Shoemaker is a specific application of eminent domain, the broader power itself. If your essay invokes eminent domain as a concept, citing Shoemaker shows you can back the abstraction with a real case, which is the whole point of strong evidence.

### Kelo v. City of New London (Topic 11.2)

Kelo (2005) stretched "public use" to include private economic development, and it sparked national backlash. Pairing Shoemaker (parks, broadly accepted) with Kelo (private developers, hotly contested) lets you show how a legal principle can drift over a century, a great move for a [qualified](/ap-lang/unit-7/considering-limitations-an-argument/study-guide/Bw4LS29KAckQKAIE20sf "fv-autolink"), nuanced thesis.

### Kohl v. United States (Topic 11.2)

Kohl (1875) was the first case confirming the federal government even has eminent domain power. Shoemaker came 18 years later and extended that power to parkland. Kohl establishes the rule, Shoemaker expands what counts as public use.

### Fifth Amendment (Topic 11.2)

The Takings [Clause](/ap-lang/key-terms/clause "fv-autolink") of the Fifth Amendment is the constitutional anchor here. It permits taking private property for public use only with just compensation. Tying Shoemaker back to the Fifth Amendment in your commentary shows you understand why the case mattered, not just that it happened.

## On the AP Exam

Shoemaker won't appear in an AP Lang multiple-choice stem, and no released FRQ has used this case by name. That's not the point. The point is what you do with it on the argument essay (Question 3). Prompts about government power, individual rights versus collective benefit, public spaces, or how communities define progress all open the door for it. To use it well, do three things. State the case accurately (1893, Supreme Court, eminent domain upheld for Rock Creek Park). Explain why it supports your claim, since evidence without explanation earns nothing on the rubric. Then push into the tension it raises, like whether "public good" is a stable idea or one that powerful institutions get to define. That last move is what separates a 4 in Evidence and Commentary from a 3.

## Shoemaker v. United States vs Kelo v. City of New London

Both are eminent domain cases, but they sit at opposite ends of the "public use" spectrum. Shoemaker (1893) approved taking land for a public park, something everyone can literally walk into. Kelo (2005) approved taking homes so a city could hand the land to private developers, on the theory that economic growth benefits the public indirectly. Shoemaker was uncontroversial; Kelo triggered laws in over 40 states limiting eminent domain. In an essay, Shoemaker is your example of the power working as intended, and Kelo is your example of it stretched to a breaking point.

## Key Takeaways

- Shoemaker v. United States (1893) affirmed that Congress can use eminent domain to acquire private land for public parks, with Rock Creek Park in Washington, D.C. as the result.
- In AP Lang, this case is evidence material for the argument essay, not a topic you'll be quizzed on directly.
- The case turns on the Fifth Amendment's Takings Clause, which allows the government to take private property for public use if it pays just compensation.
- Pairing Shoemaker with Kelo v. City of New London lets you trace how the definition of "public use" expanded over a century, which makes for a nuanced, qualified argument.
- Evidence only scores when you explain it, so always connect the case back to your claim with commentary about government power, property rights, or the public good.

## FAQs

### What is Shoemaker v. United States?

It's an 1893 Supreme Court case ruling that Congress could use eminent domain to take private land for a public park, which became Rock Creek Park in Washington, D.C. In AP Lang, it's useful as specific historical evidence for [argument](/ap-lang/unit-5/developing-commentary/study-guide/XCOsJDogjH9fPDcdbsrS "fv-autolink") essays about government power and the public good.

### Do I need to memorize Shoemaker v. United States for the AP Lang exam?

No, AP Lang never requires specific cases. But the argument essay rewards specific evidence, and a named Supreme Court case with a date beats a vague claim like "the government sometimes takes property" every time.

### How is Shoemaker v. United States different from Kelo v. City of New London?

Shoemaker (1893) approved eminent domain for a public park that anyone can use. Kelo (2005) approved it for private economic development, which was far more controversial and prompted over 40 states to pass laws restricting eminent domain. Together they show how "public use" expanded over time.

### How is Shoemaker different from Kohl v. United States?

Kohl (1875) was the first case establishing that the federal government has eminent domain power at all. Shoemaker (1893) built on it by confirming that a park counts as a valid public use. Kohl set the rule, Shoemaker widened it.

### How would I actually use Shoemaker in an AP Lang argument essay?

Use it when a prompt involves government authority, public spaces, or individual rights versus collective benefit. State the case accurately, explain how it supports your claim, then explore the tension it raises about who gets to define the public good. The explanation is what earns the points, not the citation alone.

## Related Study Guides

- [Building Strong Evidence and Commentary for the Argument Essay](/ap-lang/argument-essay/evidence-commentary/study-guide/wE6wK6rdYreIG3vJ)

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