## Facts

- Landowners Harry and Margaret Redfield bought about 97.2 acres near Des Moines in February 1956 for contemplated residential subdivision development.
- In November 1957, the Iowa State Highway Commission initiated condemnation to take the north 77.2 acres for construction of limited-access Interstate Highway 80.
- A condemnation commission awarded $70,000 in damages to the Redfields.
- The Commission took possession on December 26, 1957 and began construction.
- The Redfields appealed to district court seeking $198,925, asserting higher value based on subdivision potential.
- After a jury trial, the jury awarded $60,000; judgment was entered on that verdict.
- The Redfields appealed, challenging evidentiary rulings concerning comparable sales/recorded instruments and challenging valuation and damages instructions.

## Issues

1. Whether the trial court erred by excluding certified copies of deeds and a contract offered as evidence of comparable sales and by striking related valuation testimony.
2. Whether authenticated recorded instruments were admissible under Iowa Code §§ 622.36–622.37 as substantive evidence or for cross-examination, without additional foundation.
3. Whether the jury was properly instructed on the measure of damages for a partial taking and on considering prospective subdivision use in determining fair market value.
4. Whether the combined evidentiary rulings and instructions caused prejudicial error requiring reversal.

## Decision

- Affirmed the judgment on the $60,000 jury verdict.
- Held the exclusion of particular deeds/contract evidence and related testimony was within the trial court’s control of relevance and foundation and did not warrant reversal.
- Held Iowa Code provisions permitting use of recorded instruments did not eliminate ordinary admissibility requirements for comparable-sale evidence.
- Held the instructions correctly stated the “before and after” measure of damages for partial takings and properly allowed consideration of reasonably probable future use while barring speculative profits.
- Concluded the verdict was within the range of competent valuation evidence and did not show passion, prejudice, or legal misunderstanding.

## Legal Principles

- In condemnation valuation, evidence of other sales is admissible only upon a sufficient showing of comparability (including similarity of conditions, location, and time); admissibility rests largely in the trial court’s discretion.
- Statutes allowing recorded real-estate instruments or authenticated copies to be read in evidence do not override relevance, materiality, and foundational requirements for using those instruments as comparable-sale proof.
- In a partial taking, just compensation is measured by the difference between the fair market value of the entire property immediately before the taking and the fair market value of the remainder immediately after the taking, considering the project and resulting conditions.
- Highest and best use, including reasonably probable future development, may inform market value, but damages may not be based on speculative, conjectural future profits.
- A condemnation verdict within the evidentiary range of competent opinions will not be disturbed absent a clear showing of prejudicial error, passion, or prejudice.

## Conclusion

The court upheld the jury’s condemnation award, ruling that comparable-sale documents require proper foundational comparability and that valuation instructions correctly applied the before-and-after rule while permitting consideration of reasonably probable subdivision potential without allowing speculative profit-based damages.


Redfield v. Iowa State Highway Comm’n, 99 N.W.2d 413 (Iowa 1959)