Goodrich v. Detroit

Background

The city of Detroit passed a council resolution to open Milwaukee Avenue and asked a court to hold a jury trial to decide if taking private land was necessary and what compensation was owed. The jury found the street opening necessary and fixed total compensation at $15,214.75. The council then set an assessment district and directed that that total amount be assessed against lots in the district in proportion to the benefit each lot would receive. The plaintiffs were nearby lot owners who said they did not abut the new street and had already dedicated the part of the avenue in front of their land to the city for no cost.

Reasoning

The main question was whether these procedures violated the Fourteenth Amendment’s protection against taking property without due process. The Court explained that the statute creates two separate steps: (1) condemning and compensating land actually taken and (2) later determining which neighboring lots will be assessed for benefits. The Court held that only owners of land actually taken must receive prior notice of the condemnation, because the identity and extent of benefited owners are not known until the later assessment stage. The Court also found the council’s resolution substantially followed the statute, owners could contest their individual assessments at the apportionment hearing, and clerical errors in land descriptions were not fatal given the accurate map.

Real world impact

The ruling allows cities to proceed with street openings and later assess nearby lots without giving personal notice at the condemnation stage. Nearby owners cannot force a prior hearing on whether their lot will be included, but they can challenge the size of the assessment when their share is set. The court affirmed dismissal of the landowners’ suit.