People Ex Rel. Department of Transportation v. Clauser/Wells Partnership

In this eminent domain action brought by the People of the State of California, acting by and through the Department of Transportation (Caltrans) as plaintiff, Caltrans appeals a judgment after jury trial favoring defendant The Clauser/Wells Partnership, doing business as Manchester Auto Salvage, Inc. (Manchester) on Manchester’s claim for compensation for condemned business inventory. Caltrans asserts prejudicial evidentiary error. Caltrans also appeals a postjudgment order awarding Manchester litigation expenses and costs. We reverse the judgment and the order.

I

Introduction

Manchester operated an automobile salvage business engaged in selling auto parts on real property condemned by Caltrans to widen a freeway. By the time of trial in Caltrans’s eminent domain action, the only remaining matter for litigation was the valuation of Manchester’s business inventory. Under the Eminent Domain Law, the proper measure of compensation was the fair market value of Manchester’s business inventory taken by Caltrans. (Code Civ. Proc., § 1263.310.) The parties stipulated that Caltrans was to compensate Manchester for the fair market value of its business inventory as of December…