United States v. Goltra

Background

Edward F. Goltra leased four tugboats and 19 steel barges to operate as a common carrier for the government. In March 1923 a War Department official ordered Colonel Ashburn to take possession of the fleet and unloading facilities. Goltra sued under a special 1934 law that let the Court of Claims decide his claim for “just compensation.” The Court of Claims awarded $350,000 and six percent interest from the date of the taking to payment; the United States and Goltra’s executors both appealed parts of that ruling.

Reasoning

The central question was whether the special jurisdiction law allowed interest as part of the award for the 1923 seizure. The Court explained that interest is not normally charged against the Government unless Congress expressly permits it or the taking is a formal government taking under the power of eminent domain (a formal government taking). Earlier cases allowed interest when Congress had authorized or ratified such takings, but here the seizure was found to be tortious and not authorized or ratified in a way that converts it into an eminent-domain case. The Court therefore held the jurisdictional act, an act of grace meant to let the claim be heard, did not itself authorize interest. On the evidence issues, the Court said the trial court properly weighed and could discount remote offers to rent or comparisons to other vessels.

Real world impact

The decision removes interest from this award and leaves claimants unable to recover interest unless Congress clearly provides for it or ratifies a taking. It also confirms that trial judges have discretion to reject remote or unreliable valuation evidence in damage cases.