Jackson v. State of New York

In Jackson v. State of New York (213 NY 34, 106 N.E. 758 [1914], Cardozo, J.), the Court first applied the law of fixtures to eminent domain, recognizing that certain economic factors--unique to a functioning business--must be considered as an enhancement factor when valuing condemned property. In Jackson, claimant's property had been used as a grain and bean warehouse that housed equipment and machinery used for business purposes. The Appellate Division determined that although most, if not all, of the items would be deemed fixtures as between vendor and vendee, that conclusion was inapposite in the context of eminent domain because the State--unlike a vendee--had no use for the attached machinery. The Court rejected that distinction, concluding that condemnation is a forced sale that places the State and the claimant in the position of vendee and vendor and "on that basis their rights and duties ... must be determined" (id. at 35).