City of Pleasant Hill v. First Baptist Church

In City of Pleasant Hill v. First Baptist Church (1969) 1 Cal.App.3d 384, the city condemned for a roadway a portion of a parcel of real property belonging to the church and utilized for the meeting of the congregation and related church purposes. The church contended that the value of the remainder property had been substantially reduced because its plans for expansion were thwarted by the taking. Furthermore, because of the character of the improvements and the special use of the property by the church, the property had no readily ascertainable market value and the value of improvements was about equal to the cost of demolition. The value was significantly reduced by the taking because the few potential buyers would have the same problems in respect to expansion needs by virtue of population growth that were experienced by First Baptist Church. The appellate court in ruling evidence relevant to the decreased usability of the remainder for church purposes concluded that "if the property had lost its utility for general church purposes, the church involved not only suffered specific direct damage, but was indirectly damaged with respect to any market value of the property because of the loss of whatever potential buyers might possibly have been found for the special church use.