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United States v. Willow River Power Co.

United States Supreme Court
324 U.S. 499 (1945)

Written by Oni Harton, JD

Facts

Willow River Power Co. (power company) (plaintiff) operated a hydroelectric generating plant. Falling water from a non-navigable river to the natural level of a navigable river powered the plant. When the United States (Government) (defendant) raised the level of the navigable river by building a dam to improve its navigation, it decreased the power company’s ability to produce electricity by lessening the head of water at the power company’s dam. The court of claims found that the Government had the right to raise the level of the river to the ordinary high-water mark. The court of claims found that the Government had to compensate the power company for taking property rights when it raised the river level beyond the ordinary high-water mark.

Rule of Law

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Issue

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Holding and Reasoning (Jackson, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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