United States v. Carmack

Background

The United States sought to take about one and one-half acres of a four-acre city park in Cape Girardeau, Missouri, as a site for a post office and customhouse. The strip to be taken included a courthouse and city hall used in the park. A descendant of the original grantors contested the taking, claiming a special interest in the park from old deeds. Lower courts divided: one judge dismissed the Government’s petition as arbitrary, while the Court of Appeals found the federal officials lacked authority; the Supreme Court agreed to review the statutes.

Reasoning

The central question was whether the Federal Works Administrator and the Postmaster General, under the Condemnation Act and the Public Buildings Act, could select and condemn land held by the city for local public uses. The Court held those statutes give broad authority to the designated federal officials to choose and acquire sites for federal post-office purposes. The decision stressed federal supremacy over a clearly federal use and said the officials’ site choice was an administrative decision not subject to courts overturning the merits unless there was bad faith or a truly arbitrary, capricious selection. The record showed reasoned consideration, so the selection was lawful.

Real world impact

The ruling lets the Government proceed with condemnation for a federal post office on this city park, subject to paying just compensation. It means long-standing local public use or trust status does not automatically block a lawful federal taking. Courts will not second-guess reasonable site choices by authorized federal officials unless bad faith or clear arbitrariness is shown.

Dissents or concurrances

Justice Douglas agreed with the result and the opinion’s reasoning but reserved judgment about when authority to condemn city- or state-owned land should be inferred from a general statute if the local government mounts a direct challenge.