## Facts

- Transcontinental Gas Pipe Line Corporation operated an interstate natural gas pipeline from Texas to New York, supported by multiple compressor stations.
- The company built and operated a compressor (“booster”) station on a 24-acre tract in rural Howard County, Maryland, pursuant to federal regulatory authorization.
- Nearby landowners owned substantial residential and farm properties that predated construction of the compressor station.
- The homeowners alleged the station’s noise and vibration materially interfered with their use and enjoyment of their homes, disrupting comfort, rest, and ordinary residential living.
- The company asserted the station was necessary for an important public service, was engineered and operated carefully, and had made changes that reduced (but did not eliminate) the complained-of effects.
- Evidence included homeowner testimony about experienced noise and vibration, partial corroboration by an engineer, and the company’s reliance on sound measurements and evidence that further mitigation was not reasonably feasible.

## Issues

1. Whether the station’s noise and vibration constituted a nuisance by substantially and unreasonably interfering with neighboring homeowners’ use and enjoyment of their property.
2. Whether federal authorization and public utility function barred nuisance-based injunctive relief against the station’s operation.
3. Whether the district court properly granted equitable relief requiring abatement of the interference.

## Decision

- The Fourth Circuit affirmed the district court’s judgment.
- The court upheld findings that the noise and vibration were real, substantial, and unreasonable interferences with plaintiffs’ residential use and enjoyment.
- The court rejected the contention that the station’s public service function and federal authorization immunized it from nuisance liability or equitable restraint.
- The injunction requiring abatement of the nuisance was sustained.

## Legal Principles

- A lawful enterprise serving a public function may still constitute a private nuisance when its operations substantially and unreasonably interfere with neighboring property rights.
- Federal authorization to construct and operate a facility does not, by itself, eliminate state-law nuisance remedies for unreasonable operational impacts on adjacent landowners.
- In nuisance cases seeking equitable relief, trial courts may credit credible testimony about actual experienced interference over technical measurements, and appellate courts generally defer to supported factual findings.
- Injunctive relief may be appropriate for a continuing nuisance where operational impacts materially impair normal residential use and enjoyment.

## Conclusion

The Fourth Circuit held that a federally authorized interstate gas compressor station could be enjoined as a nuisance when its noise and vibration materially and unreasonably interfered with neighboring homeowners’ use and enjoyment of their property, and it affirmed the district court’s abatement-focused injunctive relief.


Transcontinental Gas Pipe Line Corp. v. Gault, 198 F.2d 196 (4th Cir. 1952)