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United States v. Reynolds

Facts of the Case

Provided by Oyez

The United States sued to condemn over 250 acres of W.G. and Mary Reynolds land for use in the Nolin Reservoir Project. The Fifth Amendment authorized this type of taking as long as the government provided “just compensation”. The Reynolds’ claimed that the original project did not contain 78 of the acres the United States tried to claim. A jury awarded the Reynolds’ $20,000 as compensation for all the land taken. On appeal, the U.S. Court of Appeals for the Sixth Circuit reversed and ordered a new trial, finding that the jury instructions referred to matters disclosed outside the jury’s presence. Both the trial court and the court of appeals rejected the United States’ argument that the “scope of the project” issue was a question for the judge to decide, not the jury.

Questions

  1. (1) Should a judge or the jury decide whether the 78 acres were in the initial scope of the project?

    (2) Does the “scope of the project” rule require the early planning stages to show specifically which land will be taken, or just a general area influenced by the planned project?

Conclusions

  1. The judge should decide; general area. In a 6-2 decision, Justice Potter Stewart wrote the majority opinion vacating the lower judgment and remanding to the district court. The Supreme Court held that Federal Rule of Civil Procedure 71A(h) provides that the jury is limited to deciding amount of just compensation. The trial judge should decide all other issues. The Court also briefly confirmed that the scope of the project includes any land that will likely be used according to early plans. Justice William O. Douglas wrote a dissent, stating that there is no reason to prevent the jury from deciding issues of fact, such as the scope of the project, on which its verdict will rely. Justice Hugo L. Black joined in the dissent.