McGovern v. City of New York

Background

A landowner named McGovern owned a parcel taken for a reservoir to supply water to the City of New York. State-appointed Commissioners set compensation and refused to admit certain evidence that McGovern said showed the land had exceptional value as part of the Ashokan reservoir site. McGovern argued that excluding this evidence deprived him of property without due process. The New York courts affirmed the Commissioners’ rulings, and the case reached this Court for review.

Reasoning

The Court addressed whether rejecting the offered evidence denied McGovern constitutional due process. It explained that not every mistake about damages or evidence amounts to a constitutional deprivation. The Commissioners viewed the broad offer of proof as containing inadmissible or speculative elements, and the Court agreed that enhanced value tied to a reservoir depended on the practical likelihood that many separate parcels would be combined. An owner is entitled only to the value of the part actually taken under the existing titles, and hypothetical or remote possibilities cannot inflate compensation. On that basis, the Court found no disregard of McGovern’s plain rights and affirmed the state judgments.

Real world impact

The decision means owners cannot easily claim extra payment based on speculative value from a larger public project unless that possibility actually affects market prices. It shows deference to state valuation bodies and courts unless their rulings are arbitrary. Property takings for public works, like reservoirs, can proceed without awarding enhanced sums for remote or purely hypothetical unifications of land.