Baskett v. United States

8 Cl. Ct. 201, 1985 U.S. Claims LEXIS 983
CourtUnited States Court of Claims
DecidedMay 10, 1985
DocketNos. 161-78, 340-78, 317-79L, 311-80L and 616-80L
StatusPublished
Cited by26 cases

This text of 8 Cl. Ct. 201 (Baskett v. United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baskett v. United States, 8 Cl. Ct. 201, 1985 U.S. Claims LEXIS 983 (cc 1985).

Opinion

OPINION

LYDON, Judge:

In these five consolidated cases,1 some 95 owners of some 135 tracts of land adjacent to and/or on tributaries of the Ohio River originally sued to recover damages which they allege they have incurred and are continuing to incur as a result of activities relating to the construction and operation of some 7 high-lift dams by the United States Army Corps of Engineers (Corps).2 The issues presented in plaintiffs’ petitions (complaints) are identical to those raised by 23 different owners of land adjacent to the Ohio River in Loesch v. United States, 227 Ct.Cl. 34, 645 F.2d 905, cert. denied, 454 U.S. 1099, 102 S.Ct. 672, 70 L.Ed.2d 640 (1981).3 However, the court’s ruling on defendant’s November 22,1982, “Motion In Limine”, filed pursuant to RUSCC 16, narrowed this litigation to a single issue. See Baskett v. United States, 2 Cl.Ct. 356 (1983). That single issue involves the question of whether the construction and the operation of certain high-lift dams on the Ohio River are the cause of erosion on [204]*204plaintiffs’ lands. If so, then such damage caused by the dams in question would, in effect, amount to a taking of plaintiff’s land entitling them to just compensation.4

These actions were tried by the court during the months of July, August and September 1983. The court has carefully considered the testimony and exhibits introduced in evidence during trial, as well as the post-trial submissions and oral argument of counsel, and issues this opinion setting forth its findings of fact and conclusions of law. For reasons set forth in the following opinion, the court concludes that plaintiffs are not entitled to recover on their claims.

I.

Plaintiffs in these cases are owners of land along both banks of the Ohio River and its tributaries. For a more detailed discussion of the evolution of the Ohio River than is found in this opinion see Loesch v. United States, supra. The Ohio River itself is 981 miles long and navigable for its entire length. It has always been well suited as a thoroughfare for the transportation of goods and it has been used as such for decades.

From a geology point of view, the Ohio River is considered an alluvial river in that its soil structure and flow pattern are such that its banks are constantly eroding, the eroded material is transported downstream, and eventually this matter is deposited as sediment. However, there are portions of the Ohio River banks, which are colluvial in nature, i.e., covered with rock and rock debris, or composed of bedrock where the erosive impact of the river is diminished by the more resistant surfaces. However, such resistant banks can create more meander in the river by diverting the currents toward opposite alluvial banks which will erode. The flow of the river will also act to more severely erode the outside of the bends in the river where the flow velocity is greater.

The Ohio River, has for centuries been a very dynamic river. Erosion of its banks caused by the river’s own erosive forces has created constant change on the river since its origins. The forces of the river’s flow, which varies with the precipitation in its watershed, acts to erode some banks, deposit sediment on others in a healing process, and in some instances has no effect on more stable banks. Erosion on a river of this magnitude with its unregulated flow is not a new phenomenon.

In ascertaining the specific cause of erosion, it is without question that many variables must be studied. Variations in precipitation within the river’s watershed will determine both the volume of the river’s discharge and the velocity of the flow. It is uncontradicted that during periods of heavy precipitation floods occur. These floods, which increase the velocity of the river flow as well as raise the water level, clearly cause substantial riverbank erosion. Precipitation itself can affect bank conditions and contribute to erosion damage. Land use along the riverbanks including farming, mining, and the building of homes, with their associated increased use of water and the need for drainage, can also cause and/or add to erosion of riverbanks. The existence of certain soil or rock structures either natural or man-made on the riverbanks can either contribute to or hinder erosion damage. Additionally, the construction and operation of artificial structures on rivers, such as dams, can, under some circumstances, alter the river’s natural flow pattern, sediment propensities, etc., to the extent that riverbank erosion occurs where it would not have occurred naturally. In any event, it is clear that in order to determine the cause(s) of erosion many factors including climate, soil characteristics at a particular site, river site location, land use and many other mechanisms must be considered.

As stated above, the Ohio River has been historically utilized as a means to transport [205]*205goods throughout its portion of the mid-west. As the boats which travelled the Ohio River increased in size and power and were able to haul more tonage, steps had to be taken to deepen the river channel. The use of a system of locks and dams to increase the depth of the channel began in the late 1800’s. The series of locks and dams along the Ohio River has been constantly modernized to: 1) keep up with the increasing size of vessels on the river and 2) to ensure that the increased traffic on the river would move up and down the river as quickly as possible.

This modernization effort included the construction of 49 low-lift dams on the Ohio River. Said construction was completed in 1929. However, as river vessels increased in size and the river traffic increased incredibly the low-lift dams became inadequate and often caused delay. See Loesch v. United States, supra, 227 Ct.Cl. at 38, 645 F.2d at 910. In order to alleviate the problems created by the outdated low-lift dams, a modernization program was undertaken in 1954. Under this program 19 high-lift locks and dams were to be constructed to replace the existing low-lift dams on the Ohio River. Said dams were constructed under the authority of the River and Harbor Act of March 3, 1909, 35 Stat. 817. Id. 227 Ct.Cl. at 34, 645 F.2d at 911. See, infra note 39.

As of the time of trial in this case, 18 of the 19 high-lift dams had been constructed and were operational. The benefit to navigation of these new dams was that they were fewer in number (19 as compared to 49) and they had larger locks thus eliminating the time-consuming and costly lockages necessitated by the greater number of the low-lift dams. Five of these high-lift dams are involved in this litigation. (See supra note 2.) These five dams, beginning upstream and working down, are: the Mel-dahl Locks and Dam, the Markland Locks and Dam, the McAlpine Locks and Dam, the Cannelton Locks and Dam, and the Newburgh Locks and Dam.

Meldahl Dam is located on the Ohio River at river mile 436.2, that is, 436.2 river miles below Pittsburgh, Pennsylvania. Construction on this dam and associated locks began in 1959 and was completed in 1964. The pool was then raised behind the dam until it reached its normal pool elevation of 485 feet mean sea level (m.s.l.) on March 28, 1965. Meldahl Dam and its pool replaced four low-lift dams (Nos. 31, 32, 33 and 34). The pool created by this dam covers 95.2 river miles and ends upstream at the base of the Greenup Locks and Dam. Meldahl Dam was at issue in Loesch v. United States, supra.

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Bluebook (online)
8 Cl. Ct. 201, 1985 U.S. Claims LEXIS 983, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baskett-v-united-states-cc-1985.