Appleby v. City of Buffalo

Background

A city proceeding in Buffalo sought to take about 141 acres of land under the Buffalo River, claimed by a landowner represented by a trustee, for public use. Commissioners were appointed, heard extensive testimony, viewed the property, and awarded six cents as compensation. The award was confirmed, reversed by an intermediate court that found the land valuable, and the matter was sent to the New York Court of Appeals, which upheld the commissioners’ authority to award only nominal damages and treated the river as a public, navigable highway.

Reasoning

The central question before this Court was whether the state proceedings deprived the owner of the constitutional protection against taking private property without just compensation. The Court examined the record and the state courts’ rulings and found that the owner had notice, hearings before commissioners, and multiple levels of review. Because there was evidence ranging from nominal to substantial valuations and no legal ruling prevented the owner from obtaining compensation, the Court concluded the state process satisfied the constitutional requirement and affirmed the state court judgment.

Real world impact

The decision leaves in place the state courts’ handling of this taking, including the six-cent award, and confirms that state condemnation procedures can satisfy constitutional protections when they provide notice, a hearing, and judicial review. The ruling does not require a different federal remedy and limits federal intervention where the state record does not show a clear denial of constitutional rights.