W. Va. Dept. of Transportation v. Western Pocahontas Properties

CourtWest Virginia Supreme Court
DecidedJune 17, 2015
Docket14-0381
StatusSeparate

This text of W. Va. Dept. of Transportation v. Western Pocahontas Properties (W. Va. Dept. of Transportation v. Western Pocahontas Properties) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
W. Va. Dept. of Transportation v. Western Pocahontas Properties, (W. Va. 2015).

Opinion

No. 14-0381 - West Virginia Department of Transportation, Division of Highways v. Western Pocahontas Properties, L.P.; WPP, LLC; and Beacon Resources, Inc.

FILED June 17, 2015

RORY L. PERRY II, CLERK

SUPREME COURT OF APPEALS

OF WEST VIRGINIA

LOUGHRY, Justice, dissenting:

In this case, the majority has decided to treat the State like a child, scolding it

for not adequately preparing for trial and then allowing it to have a “do over.” Despite the

fact that the new points of law set forth in the majority opinion do not support a finding that

the trial judge erred by refusing to give the State’s proposed jury instruction, the majority

nonetheless reaches that conclusion and remands this case for a new trial. In doing so, the

majority provides unprecedented, detailed guidance for the retrial of this matter in an

undisguised effort to ensure that the State is not slapped with another twenty-four million

dollar verdict. Because it is clear that the trial court did not commit reversible error by

refusing to give an obviously erroneous instruction and because this Court should not be

dispensing legal advice to parties, I dissent from the majority’s decision in this case.1

1 As discussed in the majority opinion, the State also asserted in this appeal that the trial court committed reversible error by excluding its expert’s testimony concerning sales of comparable mining properties. I agree with the majority’s finding that the trial court properly excluded this testimony because the record clearly shows that the expert’s opinion was not relevant or reliable. I dissent because of the majority’s ultimate decision to set aside the verdict and remand this case for a new trial based upon an unsupported and erroneous conclusion that the trial court erred by refusing to give the State’s proposed jury instruction.

The proceedings below focused primarily upon the fair market value of

Beacon’s interest in the subject property, i.e., its right to extract and sell the coal, which was

thwarted as a result of the State’s decision to take the land for the construction of Corridor

H. When the State initiated this condemnation proceeding, Beacon was actively surface

mining the property. As a result of the State’s taking, Beacon was forced to cease its mining

operations and go out of business. During the trial, the State, relying upon cases from 1885

and 1919,2 proposed that the following instruction be given to the jury:

You are instructed that in determining whether the residue of the property is damaged or injured, you may consider damage to the land, but you may not consider any lost profit or damage or injury to any business thereon, because such damages depend on contingencies too uncertain and speculative to be allowed. (emphasis supplied)

The trial court found the instruction would apply if the business being operated on the

property could be relocated, as would be the case with a gas station, factory, or store.

However, because the property at issue–the coal–and its location constituted the business,

the trial court determined that Beacon was entitled to the value of the property taken,

“measured by the dollar amount for which [it] could sell it.” Whitney Benefits, Inc. v. United

States, 18 Cl. Ct. 394, 409 (1989). Accordingly, the trial court refused to give the proposed

jury instruction.

2 See Gauley & Eastern R. Co. v. Conley, 84 W.Va. 489, 100 S.E. 290 (1919); Shenandoah Valley R. Co. v. Shepherd, 26 W.Va. 672 (1885).

While the general rule in the law of eminent domain has been that business

profits are not an indicator of the value of land because the success of the business depends

on the skill of the operator and the efficiency of the operation, “courts [now] recognize an

exception to this rule when the profits proceed directly out of the land condemned, thereby

contributing to its intrinsic value, as opposed to a business being conducted on the land.” 8

Nichols on Emminent Domain § G-14F.03 (3rd ed. 2015). For example, in State Highway

Commission v. Jones, 363 N.E.2d 1018 (Ind. Ct. App. 1977), the State brought an action to

condemn approximately twenty-six acres of quarry land to build a highway. After the jury

returned a verdict of nearly half a million dollars, awarding damages to both the owner

landlords and the tenants operating the quarry business on the land, the State appealed

asserting, inter alia, that the trial court had erred by excluding its instruction that would have

directed the jury not to consider “business profits or volume as evidence of the value of the

land or any interest thereon.” Id. at 1026. Finding that the trial court rightfully excluded the

instruction, the appellate court explained:

Plaintiff’s Tendered Instruction No. 1 is incorrect in that it instructs the jury not to consider business profits as an element which contributes to the value of the land. However, as it was pointed out above, where income is produced by the sale of minerals or other soil materials which are an intrinsic part of the land, then the capitalization of business profits may be proper. Therefore those profits may be considered by the jury to the extent that they reflect upon the value of the land at the time of the taking.

Id.3

In an unnecessarily long and convoluted analysis, the majority eventually

recognizes this exception to the general rule, stating that where property being condemned

was generating income, such as when minerals are being extracted, that “income may be

considered in a condemnation proceeding[.]” Maj. Op. at 20. Accordingly, the majority

holds in syllabus point two of the opinion that “the amount of raw profit lost from a business

operated either on the condemned real estate or its residue may not be the sole basis to

establish just compensation.” (emphasis added). By using the word “sole,” the majority

recognizes that profits may be considered in determining the amount of an award of just

compensation. In fact, the majority further holds in syllabus point three that “an expert

witness’s assessment of the income stream that real property produces may be relied upon

to support a fair market valuation of an interest in real estate.”

Although the majority clearly acknowledges that lost profit may be considered

in determining the fair market value of condemned property when the profit is derived

directly out of the land itself, it nonetheless finds the trial court committed reversible error

3 See also Whitney Benefits, 18 Ct.Cl. at 409 (explaining that value of coal reserves can only be measured by its ability to produce income); Foster v. United States, 2 Cl.Ct. 426, 448-49 (1983) (recognizing an operator’s interest is separate right to produce and sell minerals which is measured by estimate of what can be earned by exercise of that right).

by refusing to give the State’s proposed instruction that would have directed the jury to “not

consider any lost profit.” The majority reasons that the instruction should have been given

because Beacon’s owner, Jason Svonavec, testified he believed that the fair market value of

Beacon’s lease which allowed it to extract and sell the coal, was eighty-four million dollars.

Mr. Svonavec testified that he arrived at this figure by calculating how much profit Beacon

would have earned had it been able to extract and sell all of the mineable coal. The majority

concludes that because Mr.

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Related

West Virginia Dept. of Highways v. Sickles
242 S.E.2d 567 (West Virginia Supreme Court, 1978)
Harshbarger v. Gainer
403 S.E.2d 399 (West Virginia Supreme Court, 1991)
W. Va. Department of Highways v. Brumfield
295 S.E.2d 917 (West Virginia Supreme Court, 1982)
State Ex Rel. City of Charleston v. Coghill
207 S.E.2d 113 (West Virginia Supreme Court, 1973)
State v. Jones
363 N.E.2d 1018 (Indiana Court of Appeals, 1977)
Mainella v. Board of Trustees of Policemen's Pension or Relief Fund
27 S.E.2d 486 (West Virginia Supreme Court, 1943)
Shenandoah Valley Railroad v. Shepherd
26 W. Va. 672 (West Virginia Supreme Court, 1885)
Foster v. United States
2 Cl. Ct. 426 (Court of Claims, 1983)
Whitney Benefits, Inc. v. United States
18 Cl. Ct. 394 (Court of Claims, 1989)
United Fuel Gas Co. v. Public Service Commission
80 S.E. 931 (West Virginia Supreme Court, 1914)
Gauley & Eastern Railway Co. v. Conley
100 S.E. 290 (West Virginia Supreme Court, 1919)

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W. Va. Dept. of Transportation v. Western Pocahontas Properties, Counsel Stack Legal Research, https://law.counselstack.com/opinion/w-va-dept-of-transportation-v-western-pocahontas-p-wva-2015.