Stanley Castro Limtiaco v. United States

In 1977 Congress amended the Organic Act of Guam to permit reopening under certain conditions of proceedings in which land had been condemned by the United States between 1944 and 1963 on the Island of Guam. The amendment expressly barred review of acquisitions effected through judicial condemnation proceedings in which compensation was adjudicated “in a contested trial in the District Court of Guam.”

Plaintiffs then filed this action in the district court of Guam, alleging that lands owned by their predecessors in interest had been condemned by the United States for less than fair market value. In each of the underlying condemnation proceedings, the plaintiff’s predecessor in interest had received notice that suit had been filed in the district court but had made no appearance. The plaintiffs thus urged that there had been no prior adjudication of compensation in a “contested trial,” and that they were therefore entitled to review. The district court dismissed the actions for want of jurisdiction, holding that because the plaintiffs’ predecessors in interest had been given an opportunity to participate in the earlier proceedings, those adjudications resulted from contested…