United States v. 50 Acres of Land et al.

Supreme Court of the United States, 1984.

469 U.S. 24, 105 S.Ct. 451, 83 L.Ed.2d 376.

Johnson, pp. 865-867

Facts: The government instituted eminent domain proceedings against a landfill belonging to the city of Duncanville, Texas as part of a flood control project. The government argued that it need only pay the ordinary fair market value of the land, while the city argued that the government should pay that value plus the cost of acquiring and developing a new landfill. In the trial court, the jury found that the land was worth $225,000 and a reasonable substitute facility was worth about $700,000. The District Court entered a judgment for $225,000 plus interest. The Court of Appeals reversed and remanded, and the government appealed to the U.S. Supreme Court.

Issue: Is just compensation in this case properly measured by the cost of a reasonable substitute landfill or by the fair market value of the condemned facility?

Rule: Just compensation is generally measured by fair market value.

Analysis: The Court declines to make an exception to the rule here. It was not difficult to establish a fair market value for the condemned facility, therefore it wasn’t necessary to substitute a different measure of just compensation.

The Court emphasizes that the language of the Constitution doesn’t limit just compensation to strictly private condemnees but also to public entities at the state and local level.

The Court also emphasizes that the standard for just compensation is objective, not subjective, and doesn’t vary by whether the condemnee is a private owner or a public entity.

Conclusion: The Court of Appeals is reversed and the decision of the District Court is reinstated.

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