United States v. Lynah
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Lynah's rule requiring compensation when government works permanently flood other private land was left intact. A district court had earlier declined to apply Lynah to a flooding claim; both confirmed treatments are listed below. All 20 flagged citations have been read.
20 later cases cite United States v. Lynah; 20 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on United States v. Lynah?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Supreme Court rejected Lynah's rule allowing compensation for damage to a riparian owner's property below ordinary high water mark.
United States v. Chicago, Milwaukee, St. Paul & Pacific Railroad · Supreme Court of the United States · filed
In the Lynah case the plaintiff’s rice plantation was rendered worthless by the Government’s raising the water in the Savannah River. ... We are bound, therefore, to determine whether we shall follow that decision in respect of the issue involved in the instant case. ... But we think this Court has never followed it as a binding decision that compensation is due for injury or destruction of a riparian owner’s property located in the bed of a navigable stream. And we think that, so far as it sanctions such a principle, it is in irreconcilable conflict with our later decisions* ... and cannot be considered as expressing the law.
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Declined to follow
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The district court declined to apply Lynah to a flooding claim because it considered more recent decisions controlling.
Simmons v. United States · W.D. Kentucky · filed
United States v. Lynah, 188 U.S. 445, 23 S.Ct. 349, 47 L.Ed. 539, and United States v. Cress, 243 U.S. 316, 37 S.Ct. 380, 61 L.Ed. 746. They support the plaintiff’s contention, and if followed would require that the defendant’s motion be overruled. ... The ruling in the present case is accordingly controlled by the more recent decisions in the Horstmann and Franklin cases.
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