Landowners’ Claim Alone Established Jurisdictional Amount in Condemnation Appeal

That the landowners claimed an amount exceeding the jurisdictional minimum was sufficient to give the Supreme Court of Alabama jurisdiction, even though a holding for the condemning authority would yield an award below the requisite amount. Ala. Dept. of Transp. v. Williams, No. 1060619 (Ala. Oct. 19, 2007).

The parties in this eminent-domain case disputed how much post-judgment interest was due on a condemnation award. The landowners claimed that $47,313.92 was due, while the Alabama Department of Transportation (“ALDOT”) claimed that the correct figure was $2,239.87.

The landowners argued that the Supreme Court of Alabama (to which court ALDOT had appealed) lacked jurisdiction to hear the case. Section 18-1A-288 of the Alabama Eminent Domain Code, the landowners reasoned, provides that a party may appeal a condemnation award to the Court of Civil Appeals where “the amount involved” does not exceed $10,000, and to the Supreme Court where the amount exceeds $10,000. Because ALDOT contended that only $2,239.87 in interest was due, the landowners argued, appeal should have been made to the Court of Civil Appeals. The Supreme Court, in their view, lacked jurisdiction.

ALDOT replied only that the statute “requires that appellate jurisdiction in eminent domain cases be determined by the amount of compensation awarded for the taking.” That award was $483,000, more than sufficient to give the Supreme Court jurisdiction.

The Supreme Court held that it had jurisdiction under § 18-1A-288. It first noted that it did not need to decide whether the jurisdictional amount “must be determined by” the amount of interest in controversy, or the amount of the original compensation award. It then wrote:

The landowners contend that the postjudgment-interest award should be $47,313.92. . . . Because the total postjudgment-interest calculation from the landowners’ perspective exceeds $10,000, this case is properly within the jurisdiction of this Court. That our rejection of the landowners’ contention would result in an award of less than $10,000 does not oust this Court of jurisdiction to decide the merits of the issue before us.

The Court went on to rule for ALDOT and awarded the landowners $2,239.87 in interest.