Sunday, April 14, 2013

United States v. Miller case brief

United States v. Miller case brief summary
317 U.S. 369

Petitioner government appealed from a judgment of the United States Circuit Court of Appeals for the Ninth Circuit, which found in favor of respondent landowners in eminent domain proceedings on the ground that the district court was without jurisdiction to award government a judgment for amounts overpaid to respondents.

OVERVIEW: The government condemned a strip across landowners' lands and an action in eminent domain was tried to a jury. Landowners offered evidence as to fair market value of tracts involved on date of filing of the complaint. Government objected on the ground that, as government was definitely committed to the project, landowners were not entitled to have included in the estimate of value, as of date the lands were taken, any increment of value due to government's authorization of, and commitment to, the project. As such, the market value was determined from the date of the taking due to the authorization of the project. Since the landowners' lands were probably within the scope of the project from the time the government committed to it, the government did not have to pay any increase in value arising from the known fact that the lands would probably be condemned.

The court held that the district court was within its jurisdiction and properly ordered landowners to repay the government for the amounts the landowners had received in excess of the verdicts with interest.

The district court was dealing with money deposited in its chancery to be disbursed in connection with a pending action.

OUTCOME: The court reversed, holding that the district court was dealing with money deposited in its chancery to be disbursed under its direction in connection with an action pending before it. Notwithstanding the fact that the court released the fund to respondents, the parties were still before it and it did not lose control of the fund, but retained jurisdiction to deal with its retention or repayment as justice required.

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