Delaware River Joint Toll Bridge Commission v. Colburn

Background

Respondents are owners of New Jersey land in Phillipsburg whose rear property backed onto land the Bridge Commission bought for a highway approach and bridge abutment. The Commission was created by a 1934 Compact between New Jersey and Pennsylvania, with Congressional consent, and it acquired land, closed nearby streets, and changed grades in building the approach. Respondents sued in New Jersey courts, saying the construction deprived them of access and of light, air and view, and sought either compensation or that the Commission start proceedings to fix damages.

Reasoning

The Court examined whether the Compact’s reference to a 1912 New Jersey statute required the Commission to pay consequential damages. The Compact authorized the Commission to acquire property by purchase or by eminent domain and defined “real property” to include many interests and even “claims for damage to real estate.” But the Court concluded the Compact used the 1912 Act only as the procedural method for exercising eminent domain when needed; it did not expand the Commission’s substantive liabilities. The Court rejected the New Jersey courts’ view that the Compact and the 1912 Act imposed a new rule making the Commission liable for consequential injuries from structures built on land it owned, and it noted Pennsylvania decisions did not require a different outcome.

Real world impact

The Court reversed the New Jersey rulings and denied relief under the Compact alone for consequential damages. Recovery for similar harms depends on separate state law, not on the Compact’s procedural reference. The decision clarifies that an interstate compact supplying a procedure does not automatically create broader compensation duties.