Sacramento Area Flood Control Agency v. Dhaliwal CA3

In this eminent domain proceeding, plaintiff Sacramento Area Flood Control Agency (SAFCA) acquired a fee simple interest in, a roadway easement over, and a temporary construction easement over a portion of defendant Ranjit S. Dhaliwal’s roughly 131-acre property in the Natomas Basin for use in connection with the Natomas Levee Improvement Program. The jury awarded Dhaliwal $178,703 for the property taken and $29,100 in severance damages. Brinderjit S. Dhaliwal and Gurdeep S. Dhaliwal, as co-executors of Dhaliwal’s estate, appeal.

Dhaliwal does not contest SAFCA’s right to take the property. Rather, his challenge is limited to the compensation award. His principal contention on appeal is that the trial court prejudicially erred in allowing SAFCA to introduce evidence concerning “future access” to the property. He claims that such evidence is speculative because “[a]fter this case is concluded, the County and SAFCA would be able to deny Dhaliwal access to the property,” leaving him landlocked. We shall conclude that the trial court did not err in admitting the challenged evidence because such evidence had the potential to affect the property’s market value, it was not…