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Municipality of Metropolitan Seattle v. Kenmore Properties, Inc.

Citations: 410 P.2d 790; 67 Wash. 2d 923; 1966 Wash. LEXIS 868Docket: 37773

Court: Washington Supreme Court; February 3, 1966; Washington; State Supreme Court

Narrative Opinion Summary

This case involves an appeal by Kenmore Properties, Inc. against a judgment in an eminent domain proceeding initiated by the Municipality of Metropolitan Seattle (Metro). Metro exercised its eminent domain powers to acquire a permanent easement for an underground sewer line and temporary easements for construction. The primary legal issue centered on the adequacy of the compensation awarded by a jury, which Kenmore contested as insufficient due to alleged deficiencies in the construction plans and discrepancies between public use orders and trial stipulations. The jury awarded $819 for the permanent easement and $15.40 monthly during the temporary easement's use. The court evaluated the sufficiency of the plans, emphasizing that the substance of the information provided was adequate for assessing damages. Kenmore's objections to expert valuations were dismissed, as the jury considered all evidence, including severance damages. Additionally, the court addressed Kenmore's concerns about the limitation of compensation for the temporary easement to the construction period, affirming the award with interest to mitigate delays. The judgment was ultimately affirmed, and the procedural conduct of the trial, including the admissibility of evidence and expert testimony, was upheld. Judge Ward presided over the case as a judge pro tempore.

Legal Issues Addressed

Eminent Domain Compensation Requirements

Application: The court determined that the compensation for a permanent easement and temporary easement was appropriately calculated based on the presented evidence, despite Kenmore's objections regarding valuation methods.

Reasoning: A jury awarded $819 for the permanent easement and $15.40 monthly for the temporary easement during actual use.

Jury's Consideration of Expert Testimony in Valuation

Application: The jury was permitted to consider expert testimony and differing valuations of the easement, ultimately awarding damages that reflected consideration of severance damages.

Reasoning: Witness opinions on valuation are considered by the jury, not the court.

Sufficiency of Construction Plans in Eminent Domain

Application: The court found that the construction plans provided by Metro were sufficient to inform the property owner of the taking's impact, thus allowing for the assessment of damages.

Reasoning: The court noted that property owners have the right to detailed information regarding takings to assess resultant damages, emphasizing that the sufficiency of plans is based on their substance rather than form.

Temporary Easement Compensation

Application: The court affirmed compensation for a temporary easement limited to the duration of construction activities, with interest applied to the award to account for any delays.

Reasoning: The appellant challenges the court's limitation of damages from a temporary easement to the duration of Metro's construction activities.

Variance Between Order of Necessity and Trial Stipulations

Application: The court held that discrepancies between the public use order and the trial stipulation were not material to the adequacy of compensation, as the stipulations sufficiently protected the landowner's rights.

Reasoning: Kenmore also objects to discrepancies between the property designation in the public use order and the stipulation used at trial.