Reichelderfer v. Quinn
287 U.S. 315 (1932)

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U.S. Supreme Court

Reichelderfer v. Quinn, 287 U.S. 315 (1932)

Reichelderfer v. Quinn

No. 9

Argued October 17, 1932

Decided December 5, 1932

287 U.S. 315

Syllabus

1. Under the Act of Congress authorizing the establishment of Rock Creek Park in the District of Columbia, the lands taken for the park by purchase and condemnation were " perpetually dedicated and set apart as a public park or pleasure ground for the benefit and enjoyment of the people of the United States." By Act of a later Congress, the Commissioners of the District were directed to erect a fire engine house at a designated location in the park. Owners of neighboring land, claiming a right, in the nature of an easement, to have the land used for park purposes and no other, sought to enjoin the construction.

Held:

(1) The neighboring landowners derived no rights against the Government from the dedication of the park alone, since this constituted only a declaration of public policy by the particular Congress, which was not binding on its successors. P. 287 U. S. 318.

(2) Assuming that the building of the engine house was a diversion of the land from park uses, the change of use was within the legislative power. P. 287 U. S. 320.

2. The existence of value alone does not generate interests protected by the Constitution against diminution by the Government especially where the value was both created and diminished as an incident of the operation of government. P. 287 U. S. 319.

3. The Rock Creek Park Act directed that surrounding lands be assessed to the extent that they were "specially benefited by reason

Page 287 U. S. 316

of the location and improvement" of the park. Held, that inasmuch as the dedication of the park did not imply a promise to neighboring landowners that it would be continue in perpetuity, this was not one of the special benefits required to be assessed, and the landowners therefore derived no right to perpetual maintenance of the park by virtue of the assessment; the benefits intended to be assessed must be taken to be those obvious advantages which would accrue to lands in the vicinity of the park because of their location, and which would be reflected in their market value even though there were no guaranty that the park would be continued for any particular length of time. P. 287 U. S. 321.

4. Statutes restricting the power of government by the creation of private rights are to be strictly construed for the protection of the public interest. P. 287 U. S. 321.

5. Zoning regulations for the District of Columbia are not contracts by the government, and may be modified by Congress. P. 287 U. S. 323.

60 App.D.C. 325, 53 F.2d 1079, reversed.

Certiorari, 285 U.S. 535, to review a decree affirming a decree enjoining the Commissioners of the District of Columbia from constructing a fire engine house in Rock Creek Park.

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