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United States v. Miller

(1943)

Supreme Court of the United States - 317 U.S. 369

tl;dr:

A landowner will not receive an inflated value for condemned land when such inflation is caused by the very project that the land is condemned for.

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Facts & HoldingUnited States v. Miller case brief facts & holding

Facts:The government seized a strip of land that cut across...

Holding:The Court held that a landowner will not received an...

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United States v. Miller | Case Brief DeepDive
Majority opinion, author: Mr. Justice Roberts
Level 1
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This case concerns compensation for property taken by the government for the relocation of railroad tracks due to a potential flood. The Fifth Amendment requires just compensation for private property taken for public use, which means the full and perfect equivalent in money of the property taken. Market value is the practical standard for measuring an owner's indemnity, but different circumstances may require different measures. The value of property taken must be ascertained as of the date of taking. The owner of the property being taken is entitled to receive only indemnity for their loss, and their award cannot be increased by any gain to the taker. When only a portion of a single tract of land is taken, the owner's compensation for the taking includes any value that arises from the relationship between the part taken and the entire tract, known as severance damage. However, if the taking benefits the remainder of the tract, the benefit can be set off against the value of the land taken. The Constitution does not require payment of consequential damages for other separate tracts of land owned by the same owner that are adjacent to the taken property. If the government later decides to take these neighboring lands, it must pay their market value as enhanced by the factor of proximity. The appeals court reversed the judgment due to errors made by the trial judge.

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