United States v. General Motors Corp.

Background

An automobile company leased a large warehouse for long‑term storage and distribution of parts. During World War II, the Government condemned and took immediate possession of part of the leased space for military use for about a year. The company removed goods and dismantled fixtures; a jury later awarded about 40 cents per square foot for the year, but the company had sought to prove additional moving costs and damage to fixtures.

Reasoning

The central question was what counts as “just compensation” when the Government temporarily occupies part of a leased, equipped building. The Court explained that compensation must reflect the value of the specific interest taken — here, temporary occupancy — not simply the long‑term rental rate of an empty building. The Court said evidence of costs that would affect what a subtenant would pay (for example, reasonable moving and preparation costs) may be considered in setting the market rental for that temporary use. Separately, fixtures and permanent equipment destroyed or reduced in value are distinct property and must be paid for in addition to the occupancy value.

Real world impact

Tenants with long leases who are partially ousted can present proof of costs that would change what a temporary user would pay. The Government must also pay separately for destroyed or depreciated fixtures and equipment. The case is sent back for a new calculation under these rules, so the result can increase compensation in similar takings.

Dissents or concurrances

A concurring opinion agreed fixtures must be paid for but warned against letting broad “consequential” moving costs inflate awards; Justice Douglas (joined by Justice Black) would exclude some removal costs.