United States v. Benedict

Background

In 1918 the United States took possession of a tract along New York Bay under the Lever Act. A private party, representing ownership of the tract, sued to recover its value. Trustees had earlier purported to convey the beds of 61st, 62nd, and 63rd streets toward the Bay to New York City. The City was named in the case because of that possible interest but did not seek recovery; it claimed title to the street areas and stated their size as 81,120 square feet.

Reasoning

The core dispute was who was entitled to compensation for the land the Government took and whether the City could claim more after private parties and the City had already arranged a settlement. The trial court awarded the claimant two dollars per square foot for the whole area. A federal appeals court later held the City had good title to the platted streets and required the private claimant to assign $162,240 to the City; the trustees made that assignment and the judgment was affirmed. The City later sought a larger additional payment for the portion between high-water mark and the pierhead line, but the Court concluded the City had accepted the prior arrangement and could not now demand more.

Real world impact

The ruling affirms that the private claimant receives compensation for the Government’s 1918 taking and prevents the City from undoing its prior acceptance to seek extra shoreline money. The decision leaves interest issues between the Government and claimant addressed by a companion opinion decided the same day.