United States v. 50 Acres of Land | |
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Argued March 28, 1984 Reargued October 2, 1984 Decided December 4, 1984 |
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Full case name | United States v. 50 Acres of Land |
Citations | 469 U.S. 24 (more) |
Prior history | District Court entered judgment for lower jury reward, Court of Appeals reversed and remanded |
Holding | |
The Fifth Amendment does not require consequential damages when the market value of the condemned property is ascertainable and when there is no showing of manifest injustice. | |
Court membership | |
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Case opinions | |
Majority | Stevens, joined by unanimous |
Concurrence | O'Connor, joined by Powell |
Laws applied | |
U.S. Const. amend. V |
United States v. 50 Acres of Land, 469 U.S. 24 (1984), was a United States Supreme Court case regarding whether a public condemnee is entitled to consequential damages measured by the cost of acquiring a substitute facility if it has a duty to replace the condemned facility. The Court declined to award the costs of the substitute facility, holding that the Fifth Amendment does not require consequential damages when the market value of the condemned property is ascertainable and when there is no showing of manifest injustice.
In 1978, as part of a flood control project, the United States condemned approximately 50 acres (200,000 m2) of land owned by the city of Duncanville, Texas. The site had been used since 1969 as a sanitary landfill. In order to replace the condemned landfill, the city acquired a 113.7-acre (0.460 km2) site and developed it into a larger and better facility. In the condemnation proceedings, the city claimed that it was entitled to recover all of the costs incurred in acquiring the substitute site and developing it as a landfill, an amount in excess of $1,276,000. The United States, however, contended that proper compensation should be determined by the fair market value of the condemned facility and deposited $199,950 in the registry of the court as its estimation of the amount due.
Before trial the Government filed a motion in limine to exclude any evidence of the cost of the substitute facility, arguing that it was not relevant to the calculation of fair market value. The District Court denied the motion, noting that this Court had left open the question of the proper measure of compensation for the condemnation of public property. The court concluded that "a complete factual record should be developed from which an independent determination of the appropriate measure of compensation can be made."
At trial, both parties submitted evidence on the fair market value of the condemned property and on the cost of the substitute landfill facility. Responding to special interrogatories, the jury found that the fair market value of the condemned property was $225,000, and that the reasonable cost of a substitute facility was $723,624.01. The District Court entered judgment for the lower amount plus interest on the difference between that amount and the sum already paid. The District Court explained that the city had not met its "burden of establishing what would be a reasonable cost of a substitute facility." In addition, the court was of the view that "substitute facilities compensation should not be awarded in every case where a public condemnee can establish a duty to replace the condemned property, at least where a fair market value can be established."