United States v. 564.54 Acres of Land

Brief Fact Summary.

The federal government sued the Pennsylvania Synod of the Lutheran Church in America (Church) when the Church demanded compensation additional to the fair market value of the Church’s land when the government sought to condemn the property.

Synopsis of Rule of Law.

A private landowner whose land is taken through eminent domain is not entitled to compensation for the value from the landowner’s need for the property.

Facts.

The federal government sought to acquire land from the Southeastern Pennsylvania Synod of the Lutheran Church in America (Church). The government offered the Church $485,400 for the fair market value of the land, but the Church demanded $5.8 million to cover the costs of relocating three nonprofit summer camps that were operated on the Church’s land. The trial court ruled that the Church was not entitled to additional compensation to relocate the summer camp, and the appellate court reversed.

Issue.

Whether a private landowner whose land is taken through eminent domain is entitled to compensation for the value from the landowner’s need for the property?

Held.

No. The judgment of the appellate court is reversed. The Church is not entitled to additional compensation even if the property benefits the community or the Church uses the property for unique use. The objective fair market value is just compensation for the Church.

Discussion.

A private landowner whose land is taken through eminent domain is not entitled to compensation for the value from the landowner’s need for the property. The Taking Clause of the Fifth Amendment requires the federal government to put the owner of a condemned property in the same financial position as if the property was not taken when a property is condemned.