United States v. Miller (1943)

The government condemned a strip of various landowners' (defendants') land in 1938 to relocate railroad tracks, having committed to the relocation project back in 1937; as required by statute, it deposited $2,550 as estimated compensation for three co-tenant landowners, who each received $850 from that deposit. At trial, the government successfully objected to landowners' testimony about value increases occurring after the 1937 project commitment, and the jury awarded the three landowners less than the $2,550 deposit, resulting in a judgment against them for the excess amount already paid. The Ninth Circuit reversed, holding the district court lacked jurisdiction to order repayment and that witnesses should have been allowed to testify to unrestricted fair market value.