Danforth v. United States
Headline: Court enforces a government-written price agreement in a flood-control land taking, reverses lower court’s refusal to honor the price, but denies interest and finds no taking before payment was made.
Holding: The Court held that a government’s prior written offer fixes the price for a condemned flowage easement and that no interest is owed because a taking occurs only when the award is paid.
- Makes written government settlement offers enforceable in federal condemnation suits.
- Prevents interest before the government actually pays the court award.
- Holds construction or laws alone do not automatically create a compensable taking.
Summary
Background
A landowner east of a new set-back levee in the Birds Point–New Madrid floodway accepted a written government offer in 1932 to buy a perpetual flowage easement for $31,681.98. The Government later sought formal condemnation (a court process to take land for public use) and, after commissioners’ reports, a lower award of $17,921.70 was confirmed by the trial court. The landowner asserted the earlier written offer fixed the price and asked for interest from the time of the alleged taking.
Reasoning
The Court addressed two questions in plain terms: whether the prior written government offer could fix the amount to be paid, and when interest begins if land is taken. The Court held the accepted written offer does fix the value when the court’s condemnation process is invoked, and the trial court erred in striking the landowner’s claim on that point. On interest, the Court said a taking for which just compensation is due occurs when the award is paid; therefore no interest is owed before payment. The Court also found that neither the Flood Control Act, the completion of the set-back levee, nor emergency dynamiting in the 1937 flood amounted to a taking before payment.
Real world impact
For owners facing federal flood-control projects, a signed government price offer can control the compensation amount once the court’s condemnation power is used. However, owners cannot collect interest until the government actually pays the award. Construction or legislative steps alone do not automatically create a compensable taking under these facts.
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