United States v. Hatahley

Brief Fact Summary.

Hatahley (Plaintiff) sued the United States (Defendant) to recover damages related to Defendant’s wrongful seizure of Plaintiff’s horses and donkeys.

Synopsis of Rule of Law.

Damages calculations cannot be arbitrary and must have a basis in discernable values.

Facts.

The United States (Defendant) seized and sold horses and donkeys belonging to Hatahley (Plaintiffs), members of the Navajo tribe. Plaintiffs were awarded damages of $395 for each horse or donkey; $3,500 per Plaintiff for pain and suffering; and half of the amount Plaintiff’s herds of sheep, goats, and cattle decreased in value after the horses and donkeys were taken from 1952 to 1957.

Issue.

Did the trial court err in its calculation of damages?

Held.

Yes, the Court held that the trial court had erred in its calculation of damages.

Discussion.

The Court found the first error by the trial court was its failure to consider the cost and availability of replacement animals in its calculation of market value. While animals trained for a specific purpose are unique, they are not so unique that they cannot be replaced by similarly trained animals.

Second, the trial court erred when it calculated the loss of use damages for the herds of sheep, goats, and cattle. The Court stated that the trial court’s application of 50% of the value lost was arbitrary and speculative. There were other actual costs which the trial court could have based its calculations on, and these losses cannot extend beyond the time in which a reasonable person would have replaced the seized horses and donkeys.

Finally, the amount awarded for mental pain and suffering was equally arbitrary. Such an injury is unique to each individual, and in cases where there was no physical injury, the Court said damages are rarely awarded.