United States v. Fortier

1951-12-11
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Headline: Court rejects Government attempt to recover alleged excess sale prices from two home sellers, ruling that price caps tied to the repealed 1946 veterans’ housing law did not survive repeal and cannot be enforced.

Holding: The Court held that Congress’s repeal of the 1946 veterans’ housing law removed statutory price limits, so the Government cannot force sellers of two houses to return alleged excess payments tied to prior construction priorities.

Real World Impact:
  • Bars the Government from forcing sellers to return alleged excess sale payments after repeal.
  • Leaves veterans’ material priorities intact under the repeal proviso.
  • Requires Congress to reimpose any sale price limits clearly, not by implication.
Topics: veterans housing, price limits, statutory repeal, housing sales

Summary

Background

The federal government sued to get back allegedly excessive prices paid for two houses that were sold after World War II. The two sellers had agreed to maximum sales prices when they obtained permission to build under a wartime priorities regulation. That wartime law was repealed before the houses were sold, though a proviso said certain material priorities would remain in effect for veterans.

Reasoning

The Court considered whether the price limits the sellers had agreed to remained enforceable after Congress repealed the 1946 veterans’ housing law. The Government argued the agreed maximum prices survived as a condition of the building permission and priorities. The Court rejected that view, noting Congress, after repeal, provided veterans’ preferences and rent ceilings for certain assisted housing but deliberately did not reimpose sale price limits. Because Congress showed a contrary intent, the Court refused to read sale price restrictions into the newer law by implication and affirmed the lower courts’ rulings for the sellers.

Real world impact

The ruling means the Government cannot force these sellers to return alleged excess sale payments based on the old statute. Material priorities granted before repeal remained effective under the proviso, but the Court will not create post-repeal sale price limits when Congress chose not to impose them. The decision affirms the lower courts and resolves this dispute in the sellers’ favor.

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