Sanguinetti v. United States

Background

A landowner near the main part of Stockton, California sued the United States after a federal canal and diversion dam were built above the city. Congress authorized the canal in 1902; the work was completed in 1910, and engineers placed excavated material to form a levee and a diversion dam. After an unprecedented 1911 flood and other high-water events, waters overtopped the canal and flooded the appellant’s fields, damaging crops and trees. The land had been subject to periodic overflow before the canal, and none of it was permanently submerged or rendered unusable for farming.

Reasoning

The Court addressed whether the flooding was a "taking" that requires the government to pay under the Fifth Amendment (the rule that the government must compensate when it takes private property). Citing prior cases, the Court said compensation is required only for direct, permanent invasions or appropriations of land. Here the Court found that the overflow was not shown to be the direct and permanent result of the canal: the land had been periodically flooded before construction, any increased flooding was speculative, and the use of the land was not ousted. The Court therefore concluded there was no constitutional taking; any harm would be an ordinary damage claim in tort, and such tort remedies are not available against the United States.

Real world impact

The ruling limits property owners’ ability to get constitutional compensation for temporary or uncertain flooding caused by federal works. People with farmland or other property near government-built canals, dams, or similar projects will generally need to show a permanent, direct invasion to receive payment. Because ordinary damage claims cannot be brought against the federal government, affected landowners may lack a remedy unless the flooding amounts to a lasting appropriation or other exception applies.