Graham v. Hamilton County

266 F. Supp. 623, 1967 U.S. Dist. LEXIS 8413
CourtDistrict Court, E.D. Tennessee
DecidedMarch 31, 1967
DocketCiv. A. No. 4821
StatusPublished

This text of 266 F. Supp. 623 (Graham v. Hamilton County) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Graham v. Hamilton County, 266 F. Supp. 623, 1967 U.S. Dist. LEXIS 8413 (E.D. Tenn. 1967).

Opinion

FRANK W. WILSON, District Judge.

OPINION

This is an action for “reverse condemnation”, wherein the plaintiffs seek damages for alleged destruction of an easement of way. Plaintiffs allege that they are citizens of Georgia and other foreign staes and are owners of real property situated in Dade County, Georgia. It is their complaint that the State of Tennessee has, by the construction of Interstate Highway 24, substantially destroyed plaintiffs’ right of access over Windy Gap Road to Tennessee Highway 134. The case is before the Court upon the motion of defendant, a political subdivision of the State of Tennessee, to dismiss the complaint upon the grounds that (1) the complaint fails to state a ground upon which relief can be granted, (2) the Court lacks jurisdiction of the subject matter, (3) the action contravenes the Eleventh Amendment, United States Constitution, (4) the action is local and must be brought in the jurisdiction where the land lies, and (5) the action is not authorized by Tennessee law.

It is appropriate to first take up the issue of jurisdiction of the subject matter, for if the Court lacks jurisdiction, it can proceed no further. Defendant mounts a two-pronged attack upon the jurisdiction of the Court. One of defendant’s contentions is that an action for damages to real property is local and must be brought in the jurisdiction where the land lies. At first glance, it would appear that this case would be controlled by the principles of Still v. Rossville Crushed Stone Company, (C.A.6, 1966) 370 F.2d 324, a case which originated in this court. There the plaintiffs were residents of Georgia who brought an action for damages to Georgia residence properties allegedly caused by defendant, a Tennessee corporation, and for injunctive relief restraining defendant from doing certain acts in Georgia. The action was dismissed in this court on the basis that the doctrine of Erie Railroad Co. v. Tompkins, (1938) 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188, required the Court to apply Tennessee law to the effect that an action for injury to real property is local and Tennessee courts have no jurisdiction over such an action if the property in question is in another state. See McCormick v. Brown, (1956) 201 Tenn. 166, 297 S.W.2d 91. This reasoning was approved by the Court of Appeals and the case affirmed.

Defendant contends that the Court must apply the McCormick rule in the instant ease as well. However, for a State to take property for public use without just compensation would be a deprivation of due process of law and would violate both the Constitution of the United States (Amendment 14, Section 1) and the Constitution of the State of Tennessee (Article 1, Section 21). The Court is aware of no consent, statutory or otherwise, given by the State of Tennessee for itself or its political subdivisions to be sued in a foreign jurisdiction for damages for a taking under the power of eminent domain. Consequently, denial of access to Tennessee courts to adjudicate the issues of taking and damage could result in an unconstitutional taking of property. Accordingly, the Court is of the opinion that the Tennessee courts would not, and constitutionally could not, apply the McCormick rule to bar this action had it been brought in a state court. Thus the Court [625]*625is of the opinion that it would not lack jurisdiction of the subject matter of this action by reason of the fact that the real ■ property alleged to have been damaged lies in Georgia.

Defendant’s second argument against jurisdiction is grounded in the Eleventh Amendment of the United States Constitution, which provides that:

“The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State * * * ”

The formal defendant in this case is not the State of Tennessee, but rather Hamilton County. Ordinarily, the prohibition of the Eleventh Amendment does not apply to actions against counties, municipal corporations or other state agencies. See Lincoln County v. Luning, (1890) 133 U.S. 529, 10 S.Ct. 363, 33 L.Ed. 766; Markham v. City of Newport News, (C.A.4, 1961) 292 F.2d 711; Louisiana Highway Commission v. Farnsworth, (C.A.5, 1935) 74 F.2d 910; City of Memphis, Tennessee v. Ingram, (C.A.8, 1952) 195 F.2d 338; Pettibone v. Cook County, Minnesota, (C.A.8, 1941) 120 F.2d 850.

However, “the question whether a suit is within the prohibition of the eleventh amendment is not always determined by reference to the nominal parties on the record.” In Re Ayers, (1887) 123 U.S. 443, 8 S.Ct. 164, 31 L.Ed. 216; Poindexter v. Greenhow, (1885) 114 U.S. 270, 29 L.Ed. 185, 5 S.Ct. 903. This is an especially apt point in the instant situation, because of the somewhat peculiar rules of law in Tennessee relating to actions by landowners claiming a taking of property for highway purposes. It was made clear by the Supreme Court many years ago that the Eleventh Amendment test is one of substance and not of form. As was said in the Ayers case:

“Whether (the State of Virginia) is the actual party, in the sense of the prohibition of the constitution, must be determined by a consideration of the nature of the case as presented on the whole record.”

Likewise, in the case of Hopkins v. Clemson Agricultural College, (1910) 221 U.S. 636, 31 S.Ct. 654, 55 L.Ed. 890, it was said:

“ * * * looking through form to substance, the 11th Amendment has been held to apply, not only where the state is actually named as a party defendant on the record, but where the proceeding, though nominally against an officer, is really against the state, or is one to which it is an indispensable party.”

It appears that, in Tennessee, property owners who allege that their property has been taken for highway purposes may file suit against the county where the land lies, but not directly against the State, owing to principles of sovereign immunity. However, it further appears that the State has provided by statute that liability for takings for highway purposes shall be the responsibility of the State, and not of any county, T.C.A. § 54-511. Thus, although suit may not be had directly against the sovereign, the sovereign has unequivocally assumed ultimate liability for highway takings, to the express relief of the nominal obligor, the county concerned. Most enlightening on this subject is the opinion of Mr.

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Related

Poindexter v. Greenhow
114 U.S. 270 (Supreme Court, 1885)
In Re Ayers
123 U.S. 443 (Supreme Court, 1887)
Lincoln County v. Luning
133 U.S. 529 (Supreme Court, 1890)
Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Petty v. Tennessee-Missouri Bridge Commission
359 U.S. 275 (Supreme Court, 1959)
City of Memphis, Tennessee v. Ingram
195 F.2d 338 (Eighth Circuit, 1952)
Brooksbank v. Leech
332 S.W.2d 210 (Tennessee Supreme Court, 1959)
Louisiana Highway Commission v. Farnsworth
74 F.2d 910 (Fifth Circuit, 1935)
Pettibone v. Cook County, Minnesota
120 F.2d 850 (Eighth Circuit, 1941)
Baker v. Donegan
47 S.W.2d 1095 (Tennessee Supreme Court, 1932)
McCormick v. Brown
297 S.W.2d 91 (Tennessee Supreme Court, 1956)

Cite This Page — Counsel Stack

Bluebook (online)
266 F. Supp. 623, 1967 U.S. Dist. LEXIS 8413, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graham-v-hamilton-county-tned-1967.