United States v. Central Eureka Mining Co.

Background

In 1942, the War Production Board ordered nonessential gold mines to stop operating so equipment and manpower could be used for the war effort. The Government did not occupy or physically take the mines or their equipment. Owners and operators of the affected gold mines sued the United States in the Court of Claims, arguing that the shutdown was effectively a taking of their right to mine gold. The Court of Claims found for the mine owners, and the case later reached the Supreme Court. The Supreme Court issued its decision on June 16, 1958, in an opinion by Justice Burton.

Reasoning

The Court considered whether the Board’s order amounted to a taking under the Fifth Amendment and what effect a Special Jurisdictional Act of July 14, 1952 had on claims. The Court held that the 1952 statute simply waived defenses based on the passage of time and did not direct courts to award compensation. The Court also found that the shutdown order did not constitute a taking of private property for public use. Based on those conclusions, the Supreme Court reversed the Court of Claims and denied compensation to the mine owners.

Real world impact

As decided here, gold mine owners affected by the 1942 order cannot recover compensation under the Fifth Amendment for that wartime shutdown. The ruling clarifies that Congress’s 1952 law did not create a new right to payment but only removed time-based defenses. The decision supports the Government’s power to issue wartime production orders without automatic compensation when there is no physical seizure.