United States v. Hatahley
United States Court of Appeals for the Tenth Circuit
257 F.2d 920 (10th Cir. 1958)
Hatahley and other Navajo tribal members (plaintiffs) sued the United States (defendant) after federal agents wrongfully seized their horses and donkeys and sold them to a horsemeat plant and glue factory. The plaintiffs did not prove the animals' replacement cost, arguing the animals were specially trained and irreplaceable. The trial court used estimated trade values instead of replacement cost, awarded a flat sum per animal, awarded a lump-sum reduction in the value of the plaintiffs' other livestock herds, and awarded an identical pain-and-suffering amount to every plaintiff. The United States appealed the damages award.
Whether a damages award must be based on evidence of replacement cost and individualized loss, rather than a court's own estimate or a uniform lump-sum figure, in order to restore an injured party to the position it would have occupied absent the wrong.