Summary of United States v. Hatahley
Facts: Plaintiff Navajo tribe members had been grazing burro and horses on federal lands. Gov’t and white ranchers filed suit to stop grazing, meanwhile in 1957 US Gov’t agents seized burros and horses and sold them to glue factory. The government ignored the process, they took the law into their own hands. Navajos sued under Tort Claims Act (which allows for recovery for behavior that would violate state tort law if done by private citizens). Judgment was entered for the Navajos for total sum of $186,017.50, with value of each horse and burro set at $395, each plaintiff received $3500 for mental pain and suffering.
Procedural History: In the 10th Circuit U.S. Court of Appeals, the Government is appealing the decision of the District Court for Utah. Originally the US Supreme Court held that the killing of the horses was a trespass under Utah law and therefore a violation of Tort Claims Law, the case was sent back to the District Court to determine damages, which are being appealed by the Government to the 10th circuit.
Issue: How are compensatory damages calculated under the Federal Tort Claims Act? Do you have to prove your damages according the law to recover?
Holding: Damages are calculated to place the aggrieved party in the position they would have been in had there been no injury, and in a specific, objective market-driven manner.
Judgment: Reversed and remanded for new trial as to damages, with recommendation that trial judge recuse himself due to his “incensed and embittered” attitude towards the US Gov’t.
Reasoning: Due process case. Removal of animals required a judicial decision, government resorted to self-help, thereby violating the property rights of the Navajo.