Background
In 1978, as part of a flood control project, the United States condemned approximately of land owned by the city ofProcedural history
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."''50 Acres of Land'', 529 F. Supp. at 222. The court found no basis for departing from the market value standard in this case, and reasoned that the application of the substitute facilities measure of compensation would necessarily provide the city with a "windfall." The Court of Appeals reversed and remanded for further proceedings. It reasoned that the city's loss attributable to the condemnation was "the amount of money reasonably spent . . . to create a functionally equivalent facility."''50 Acres of Land'', 706 F.2d at 1360. If the city was required, either as a matter of law or as a matter of practical necessity, to replace the old landfill facility, the Court of Appeals believed that it would receive no windfall.Opinion of the Court
The Court held that the Fifth Amendment does not require that the United States pay a public condemnee compensation measured by the cost of acquiring a substitute facility that the condemnee has a duty to acquire, when the market value of the condemned property is ascertainable and when there is no showing of manifest injustice. Rather, ''"Just compensation"'' under the Fifth Amendment normally is to be measured by the market value of the property at the time of the taking, and this case is not one in which an exception is required because fair market value is not ascertainable. The testimony at trial established that there was a fairly robust market for sanitary landfill properties. The Court did also not believe that an award of compensation measured by market value here to be fundamentally inconsistent with the basic principles of indemnity embodied in the Just Compensation Clause. In addition, the Court held that the text of the Fifth Amendment does not mandate a more favorable rule of compensation for public condemnees than for private parties. The reference to ''"private property"'' in theSee also
*References
External links
* {{caselaw source , case=''United States v. 50 Acres'', {{Ussc, 469, 24, 1984, el=no , justia=https://supreme.justia.com/cases/federal/us/469/24/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep469/usrep469024/usrep469024.pdf , oyez =https://www.oyez.org/cases/1984/83-1170 United States Supreme Court cases United States Supreme Court cases of the Burger Court Judicial remedies Takings Clause case law 1984 in the environment 1984 in United States case law United States in rem cases Dallas County, Texas