United States v. Miller

The United States (government) (plaintiff) condemned a strip across the land of various landowners (defendants) in order to relocate railroad tracks. The government committed to the relocation project on August 26, 1937. On December 14, 1938, the government filed an eminent-domain action against the landowners and a declaration of taking in the United States District Court for the District of Northern California. As part of the statutory requirement for filing the declaration, the government submitted a $2,550 deposit, which was the estimated amount of compensation due to three co-tenant landowners. The court paid each landowner $850 from the deposit. During the eminent-domain trial, various landowners offered opinion evidence regarding the fair market value of their land as of the 1938 court action. The government objected to the landowners’ testimony regarding value increases that occurred after the government’s commitment to the project in 1937. The court sustained the objection. The three landowners received a jury award under $2,550. The court entered judgment against them for the deposit amount received in excess of the award. The landowners moved to set aside the judgment. The motions were overruled, and the landowners appealed. The United States Court of Appeals for the Ninth Circuit reversed the judgment, finding that the district court lacked jurisdiction to issue an award for the excess amount, the witnesses should have been allowed to testify to fair market value without qualification, and the lands’ value should have been based on that amount.