United States v. Highsmith

Background

The dispute involved the Government and a landowner who appealed from an award made by condemnation commissioners and tried the case to a jury. Jurors were told that whether interest should be awarded was a question of law. The form of verdict given to jurors directed that interest at six percent be added from April 19, 1912, the date the land was appropriated. By agreement, the court entered a separate order requiring the deposit of interest so that a writ of error could be taken on that point. Jurors were also instructed to assess compensation based on the land's value on April 19, 1912 and not to add interest from that date to the verdict total.

Reasoning

After trial, the District Court entered final judgment requiring the deposit of the verdict amount and a separate order directing payment of interest from April 19, 1912. The Government appealed, and the Circuit Court of Appeals reviewed the facts and treated the case as governed by the court’s decision in a companion case (United States v. Rogers). The Circuit Court affirmed the judgment. The Supreme Court agreed with the Circuit Court’s conclusion and affirmed that judgment.

Real world impact

The decision leaves in place the lower courts’ approach: the Government must pay interest measured from the date of appropriation where the court ordered it, and courts may use a separate order about interest to allow appellate review. The ruling resolves the parties’ dispute by affirming the judgment that required interest payment from April 19, 1912.