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Keywords

damagesobjectionsustainedoverruled

damages

Related Cases

Kansas v. Colorado, 533 U.S. 1, 121 S.Ct. 2023, 150 L.Ed.2d 72, 31 Envtl. L. Rep. 20,744, 01 Cal. Daily Op. Serv. 4764, 2001 Daily Journal D.A.R. 5871, 14 Fla. L. Weekly Fed. S 323, 2001 DJCAR 2918

Facts

The Arkansas River rises in Colorado and flows through Kansas and other states before emptying into the Mississippi River. In 1949, Congress approved the Arkansas River Compact, which prohibited future developments that would materially deplete the river's waters. Kansas filed a complaint in 1986, alleging that Colorado's groundwater pumping violated the Compact. A Special Master found that Colorado's actions had materially depleted the river's waters and recommended damages to Kansas, which included prejudgment interest.

The Arkansas River rises in Colorado and flows through Kansas and several other States before emptying into the Mississippi River. In 1949, Congress approved the Arkansas River Compact (Compact), which Colorado and Kansas negotiated, and which provided in Article IV–D that, inter alia, future development of the river basin could not materially deplete the usable quantity or availability to other users of the river's waters.

Issue

The main legal issues were whether Kansas could recover monetary damages from Colorado without violating the Eleventh Amendment, whether prejudgment interest should be awarded, and how to calculate the damages resulting from Colorado's violations of the Compact.

Rule

The court ruled that a state may recover monetary damages from another state in an original action without violating the Eleventh Amendment. It also established that prejudgment interest can be awarded on unliquidated claims and that the rates for such interest should reflect those applicable to individuals rather than lower rates available to states.

The court ruled that a state may recover monetary damages from another state in an original action without violating the Eleventh Amendment.

Analysis

The court applied the rule by determining that Kansas had a direct interest in the case and was not merely acting on behalf of individual farmers. It overruled Colorado's objections regarding the Eleventh Amendment and the award of prejudgment interest, concluding that the Special Master properly calculated the damages based on the difference in crop yields and that the interest should begin accruing from 1969, when Colorado knew or should have known of its violations.

The court applied the rule by determining that Kansas had a direct interest in the case and was not merely acting on behalf of individual farmers.

Conclusion

The Supreme Court ordered that Colorado's exceptions were sustained in part and overruled in part, Kansas' exception was overruled, and the case was remanded for further proceedings.

Ordered accordingly.

Who won?

Kansas prevailed in the case because the court found that it had a direct interest in the damages claimed and that the award of damages and prejudgment interest was justified based on the evidence presented.

Kansas prevailed in the case because the court found that it had a direct interest in the damages claimed.

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