People ex rel. Dept. of Transportation v. Southern Cal. Edison Co

In People ex rel. Dept. of Transportation v. Southern Cal. Edison Co. (2000) 22 Cal. 4th 791, the condemnee agreed the state could take possession of the property in 1969. The parties desultorily negotiated the price in the following years, but no compensation was paid for over 30 years until the condemnee filed an inverse condemnation action demanding compensation. (Edison, supra, 22 Cal. 4th at pp. 795-796.) In finding that section 1268.310 should not control, the court stated, "we believe this case presents the rare situation where the literal application of a statute contravenes the legislative intent behind its enactment and extends its reach far beyond those situations contemplated by the Legislature. Ordinarily, the literal meaning of the words of a statute governs. We will not, however, apply the literal language of a statute 'when to do so would evidently carry the operation of the enactment far beyond the legislative intent and thereby make its provisions apply to transactions never contemplated by the legislative body.' 'A code may strive for comprehensiveness, but exceptional situations will arise.' As a result, we may decline to apply a statute in those rare cases where 'it is obvious that the Legislature cannot have intended the statute to apply.' These principles of statutory construction are especially germane in the eminent domain context because 'the amount to be paid for property taken by the government is, under the Constitution, a matter for the courts rather than the Legislature . . . .' Thus, courts have eschewed a literal application of our eminent domain statutes if such an application 'ignores' the purpose behind the statutes. Courts have also found one of these statutes inapplicable where the Legislature did not anticipate the particular facts of the case and undoubtedly did not intend for the statute to apply there. Finally, courts have refused to apply our eminent domain statutes where their application would give the condemnee a ' "windfall" ' not intended by the Legislature. " (Edison, supra, 22 Cal. 4th at pp. 798-799.)