Joslin Manufacturing Co. v. City of Providence

Background

Several property owners challenged a Rhode Island law that lets the City of Providence and its Water Supply Board study, plan, buy, or condemn lands and water rights in a defined watershed to provide a public water supply. The challengers include a cotton-mill owner and taxpayer, an electric company with power plants and machinery, and a homeowner with water rights. The statute authorizes acquisition, describes what compensation may include (machinery removal costs, building contents, police costs, loss of nearby land value, limited employment loss, and injury to businesses established before the law), allows the city to sell or lease lands held to protect water purity, and permits supplying water to nearby communities at wholesale rates.

Reasoning

The Court considered whether the law violated the Fourteenth Amendment by unfairly burdening Providence taxpayers, creating improper classifications, allowing takings without prompt payment, or giving the city sole power to decide necessity. The Court upheld the statute. It found that protecting other communities in the watershed and using wholesale rates was within legislative discretion. Limiting certain business damages to enterprises begun before the law, and the geographic limit on moving machinery, were reasonable classifications. The statute’s compensation procedures—immediate payment if agreed, or a jury or commission process with execution against the city and a one-year possession protection—satisfied due process. Finally, the Court held that determining the public necessity to take property is a legislative question the city may decide within the law’s fixed area.

Real world impact

The ruling affirms that Providence may proceed with planned waterworks and condemn property within the specified area. Property owners retain statutory routes to contest and obtain compensation, though the city may control the initial necessity decision. The state-court decree is affirmed.