Hayes v. Port of Seattle

Background

A private contractor obtained a state contract in 1896 to excavate Smith’s Cove Waterway and use the dredged material to fill adjacent tide and shore lands, with a lien for payment. Work began but stopped after the State changed required bulkhead plans and failed to provide a promised right of way; the contractor never resumed substantial work. In 1911 the Port of Seattle was created, and in 1913 the legislature vacated part of the waterway and vested the title in the Port, which then took possession and made extensive improvements before the contractor sued in 1914 to block the 1913 law.

Reasoning

The Court addressed whether the 1913 law impaired the contractor’s contract or took property without due process. It found the statute did not change the contractor’s contractual rights or reduce his measure of recovery; the contract’s obligations survived and would govern any damage claim. The Court also found the taking served a public purpose and that state law provided an adequate way for anyone with a claim to sue the State and receive payment, including procedures for filing suit, judgment, and payment from the state treasury. Finally, the Court agreed the contractor had waited too long to seek equitable relief: because the Port had already spent large sums and conditions changed, the delay (known in equity as laches) barred undoing the Port’s improvements.

Real world impact

The decision lets the Port keep control and continue improvements on the vacated waterway while preserving the contractor’s right to seek money damages under the State’s compensation procedures. It limits courts’ power to stop public works when a claimant long delays asserting rights.