## Facts

- The United States condemned about 50 acres in Duncanville, Texas, used by the City of Duncanville as a sanitary landfill, for a federal flood control project.
- The landfill had been operated by the City since 1969.
- After the taking, the City acquired a 113.7-acre site and developed a larger, improved landfill to continue providing landfill services.
- The City sought compensation equal to its costs to acquire and develop the substitute landfill, exceeding $1.276 million.
- The United States asserted that compensation should be limited to the condemned landfill’s fair market value and deposited $199,950 as its estimate.
- Evidence at trial addressed both market value and substitute-facility costs, and the market value of sanitary landfill property was treated as measurable.

## Issues

1. Whether the Just Compensation Clause requires compensation to a public owner based on the reasonable cost of acquiring and developing a substitute facility, rather than fair market value, when market value is ascertainable and no manifest injustice is shown.
2. Whether a public entity’s duty to replace a condemned public facility constitutionally warrants a more favorable compensation measure than that applied to private owners.

## Decision

- The Supreme Court unanimously reversed the Fifth Circuit.
- The Court held that the Fifth Amendment does not require compensation measured by substitute-facility cost when the property’s market value is ascertainable and no manifest injustice is demonstrated.
- The Court reaffirmed fair market value as the presumptive measure of just compensation and rejected a special rule favoring public condemnees.
- The case was remanded for proceedings consistent with applying the fair-market-value measure.

## Legal Principles

- Just compensation is normally measured by the property’s fair market value at the time of the taking, i.e., the cash price a willing buyer would pay a willing seller.
- The Takings Clause applies the same compensation principles to public and private owners; condemnation of state or local government property by the United States is compensable, but not on more generous terms.
- The Fifth Amendment generally does not require consequential damages stemming from a taking, including increased costs of replacing a facility.
- Replacement-cost or “substitute facilities” measures are exceptional and are relevant only where market value cannot be determined or where market value would cause manifest injustice; compensation should rely on objective valuation rather than owner-specific needs.
- A prior decision associated with the “substitute facilities” concept was read as permitting, not requiring, provision of an in-kind substitute and did not establish a constitutional entitlement to replacement-cost compensation.

## Conclusion

The Court held that a city whose public facility is condemned is ordinarily entitled to fair market value, not the cost of acquiring and developing a replacement facility, when market value is ascertainable and awarding it would not be manifestly unjust.


United States v. 50 Acres of Land, 469 U.S. 24 (1984)