Property Rights

Lessons of an Effort to Compensate Victims of an Unjust Use of Eminent Domain a Century after it Happened

Los Angeles County, California, plans to return land unjustly seized from a black family in 1924.

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Manhattan Beach, California.

 

Authorities in the City of Manhattan Beach, California recently voted to return property unjustly seized by eminent domain, from an African-American family back in 1924:

On Tuesday, the Los Angeles County Board of Supervisors voted 5-0 to return the property to the descendants of Willa and Charles Bruce.

The Bruces bought the first of two ocean-view lots for $1,225, a property that could now be worth millions.

In 1924, the city of Manhattan Beach used eminent domain to force the couple off their land to turn it into a park. The city seized the property in 1929, however, it remained vacant for decades.

Following Tuesday's vote, the Los Angeles County Chief Executive Office will file a report within 60 days with a plan and timeline to return the property to the Bruce family….

"This was an injustice inflicted upon not just Willa and Charles Bruce, but generations of their descendants who almost certainly would have been millionaires if they had been able to keep this property and their successful business," Los Angeles County District 4 Supervisor Janice Hahn said. Hahn's district includes the Manhattan Beach property to be returned to the family….

"This was an injustice inflicted upon not just Willa and Charles Bruce, but generations of their descendants who almost certainly would have been millionaires if they had been able to keep this property and their successful business," Los Angeles County District 4 Supervisor Janice Hahn said. Hahn's district includes the Manhattan Beach property to be returned to the family.

The injustice the County is trying to remedy is a real one. City authorities seized the Bruce family's valuable property for what turned out to be no good purpose.

Media accounts of this case tend to assume that the land must have been condemned at least in part because of racial bias. That is entirely plausible. There is a long history of using eminent domain, zoning, and various other types of land-use restrictions to force out African-Americans. At the same time, it is possible that race was not the decisive factor in this particular case, since 25 of the 30 lots condemned for this project were owned by whites.

Whether motivated by racism or not, the takings were still deeply unjust. Destroying homes and business for a park that was never built is indefensible.

How much justice can be achieved by giving the land to the Bruce family's descendants almost a century later is debatable. The original victims  of the injustice are long-dead. Some of their descendants are still alive, and it can be argued, as County officials have, that these descendants would be millionaires today, if only the property had stayed in the family.

Perhaps that is true. But, if history had taken a different, more just, course, these particular descendants probably would never have been born in the first place. Even a slight change in the course of events is enough to prevent a particular sperm and egg form meeting at a given time, and therefore prevent the birth of a specific person. The Bruce family might well still have descendants in this counterfactual world. But they would almost certainly be different people from those that exist in our world, today.

This problem is not unique to the Manhattan Beach case. It bedevils almost any effort to provide restitution for injustices that occurred many decades or centuries in the past. An example from my own family history illustrates the problem.

Back in 1918, the newly installed communist government of the Soviet Union unjustly seized my great-grandfather's small business (and, of course, many others like it). Returning the land to me and his other descendants today is a questionable remedy. After all, neither I nor his other living descendants would ever have existed had history taken a different course back then.

These problems should not prevent compensation of still-living victims of historic injustices, or children of theirs born before the injustice occurred. But the further removed in time we are from the injustice in question, the more likely it is that the only people we can provide compensation to are ones that probably would never have existed at all if the injustice had never been committed.

The obvious lesson here is that it is essential to avoid perpetrating such injustices to begin with. If they are committed, nonetheless, it is essential to provide restitution sooner, rather than later. Getting around to it many decades after the fact is simply too late.

But while it may be impossible to truly reverse the wrong committed in Manhattan Beach back in 1924, there is much to be done to prevent similar wrongs today. Sadly, the use of eminent domain to seize property for projects that never pan out, remains all too common.

It happened in the notorious case of  Kelo v. City of New London, in which multiple homes were seized for a flawed "economic development" project that never got built, leaving a colony of feral cats as the only regular users of the condemned land. Much the same thing occurred in the recent Foxconn debacle in Wisconsin. Just last year, the New York Court of Appeals (that state's highest court), upheld a taking for a pipeline that might well never get built.

In my view, takings for projects that never get built violate the constitutional requirement (embedded in both the Fifth Amendment of the Federal Constitution and similar clauses in virtually every state constitution) that eminent domain can only be employed for a "public use." There can be no "public use" where the supposed purpose of the taking was never carried out, and especially not if this failure is predictable at the time of the taking. Even those who believe that "public use" should be defined broadly, should be able to agree that the government at least has a duty to take property only in cases where the claimed public use will actually occur.

State and federal courts should therefore crack down on takings of this type, by requiring the government to provide strong evidence that the condemned land really will be used for the project that supposedly justifies the use of eminent domain in the first place. Some states already have fairly strong enforcement of such constraints. But many do not. If judges are unwilling or unable to take this step, legislatures can enact reforms to the same effect.

Fixing this problem will not end all problematic takings. Eminent domain abuse is a complex, multifaceted issue that cannot be addressed through any one single reform. But preventing future takings like the one in Manhattan Beach would be a good place to start. The best way to deal with unjust takings is to prevent them from happening in the first place.

NEXT: Are Sunstein and Vermeule Offering a Defensive Crouch Administrativism?

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  1. Doesn’t seem to concern anyone that there is no historical record relating to the claims of eminent domain and racism. It is all lost to the mists of time except for an “activist” who claims through oral history that it happened. Of course, in the name of “justice” the local taxpayer just got fleeced a few cool million. But hey….

    1. Where are you getting that from? I didn’t see the word “activist” in the linked story.

      1. This is PC bullshit. They are getting this fake compensation because they are Democrats. $15000 is $750000 today. That seems fair for that property at the time. Everyone is sick of those America hating Democrats’ fake boohooing on TV.

    2. That’s merely a bunch of lies you just made up. There is ample documentary evidence of a) property ownership, b) eminent domain, and c) racist motivations for the ED taking. The aim was explicitly stated, at the time, to be to get rid of the unwanted black visitors.

      1. Well, are the White families getting compensated as well?
        Methinks there is a major issue of racism if they aren’t….

        Remember too that shorefront property wasn’t considered valuable in the days before central heating, weathertight houses, and clothes driers — what is now a home with a lovely view was a cold, damp hovel without the ability to dry clothes on the line, as was the custom at the time.

        1. It was a working business making a small fortune, at the time. That was not compensated for when it was seized.

  2. What I would like to know is whether the other 30 lot holders descendants will get their property back too? It seems illegal racial discrimination to provide redress for one family because of their race, but ignore the other families because they are the wrong color. Unless of course the other lot owners received a much higher purchase price and they were adequately compensated at the time.

    It also seems fair to deduct the original purchase price and accrued interest from the compensation the family’s heirs receive.

    1. According to the linked story “The Bruces and their customers were harassed and threatened by their white neighbors, including the Ku Klux Klan, the county board of supervisors said in a news release.”

      1. Yeah I heard some vague word of mouth story 100 years ago related by an activist definitely justifies depriving a whole group of compensation based on skin color.

        1. Does it bother you, Prof. Somin, that your libertarian content enrages most Volokh Conspiracy commenters — and that so many fans of this blog are old-timey bigots?

          You deserve better.

          1. Yeah, Rev, you lefties are a bunch of old time bigots. it’s a shame they have to put up with you.

            I, too, would like to know if all the plots are being returned to the families they were stolen from, or if it’s only the families with the politically approved skin color who are getting restitution.

            OTOH, I expect that the other families can sue, and will win, if Manhattan Beach is engaging in racial discrimination here

          2. Ya. It is weird how a blog focused on legal issues attracts such vile.

            1. Weird how some of us believe that a law stating “thou shalt not discriminate” actually means that….

      2. Well I’m not saying everyone was going to be overly friendly to a colored family moving in back in the ’20s, but it should be a matter of public record whether this particular family was treated equitably with the other 30 families that had their properties forcibly acquired. If the city did treat them inequitably, then I don’t oppose them being made whole.

        But if everyone was treated the same then, they should all be compensated now equally.

        I don’t see how that is objectionable.

  3. If youre a certain skin color eminent domain has a random chance of not applying to you anymore. I guess thats a partial solution.

  4. It was seized for a park and remained vacant. In other words, a park.

    Any descendants related to a member of council?

    1. I don’t think vacant necessarily means its a park.

  5. “Back in 1918, the newly installed communist government of the Soviet Union unjustly seized my great-grandfather’s small business (and, of course, many others like it).”

    OMG He is equating a seizure without compensation by a revolutionary Communist government with a US city using a constiutionial procedure to pay owners for land to be used for a public purpose, a park.

    1. Conservatives for Eminent Domain!

      1. The party of Trump supports stealing land from old ladies and Americans with land along the border. Of course the party of Bush supported George Wu Bush using eminent domain to build an obsolete ballpark…but he was doing it in the name of Jesus Christ and not a private company. 😉

        1. What could be a more obvious (and necessary) public purpose than a border wall?

      2. Why not? It certainly comports with the original understanding of the constitution.

        I don’t think there is anything controversial about the use of eminent domain for roads schools, parks, even railroads and pipelines. It’s urban renewal and other private uses that are controversial.

        1. I disagree with the assertion that everything the constitution endorsed is now all of a sudden conservative. The constitution also endorsed a tariff based economy and the draft.

          If the government wants property they can buy it on the private market. There are certain issues with that, but not so much that can’t be overcome by a clever enough market design.

          1. <bConservative:
            1. averse to change or innovation and holding traditional values.

            2.a person favoring free enterprise, private ownership, and socially traditional ideas.

            The constitution surely espoused some radical views, but they are by definition traditional views now.

            Holding an originalist view of the constitution is a conservative value, that shouldn’t be a surprise. Even if it’s something weird like free speech, owning guns, or private property giving way to imminent domain on rare occasions in a manner allowed by the constitution and established law.

      3. “Conservatives for Eminent Domain!”

        Sure, why not? Its a long recognized procedure authorized by the Constitution. Fair market compensation is required.

        How do you think roads get built? Or electric lines strung?

        1. I think eminent domain clearly gets overused, and used in cases where the end goal isn’t public use.

          I think eminent domain generally cheats the person losing the property, that the price assigned to the property as a usual matter doesn’t actually compensate the owner fully.

          But it’s absolutely constitutionally permitted, and does have at least SOME legitimate applications.

    2. “OMG. He is equating a seizure without compensation by a revolutionary Communist government with a US city using a constitutional procedure to pay owners for land to be used for a public purpose, a park.”

      I respectfully suggest that you’ve misread Somin’s comment. I think that he is assuming for the purpose of making his point that the county’s taking was unjust and on that basis comparing it to another unjust taking. I don’t think he is saying that an unfair eminent domain proceeding is the same as communist rule.

      1. I do not think so. He is calling both “unjust”.

    3. The documents show that this was a seizure without compensation, Bob. That’s why the comparison holds up. The black owners were not given fair compensation, or anything like it, for the value of their business.

    4. Uh, I think his point is that if the descendants of those who were dispossessed by L.A. County are entitled to get their property back, then the descendants of those who were dispossessed “without compensation by a revolutionary Communist government” should have an even greater right to get their property back, which means, conversely, that if even the descendants of those who suffered that much greater injustice aren’t so entitled (and they aren’t), then the descendants of those who suffered from “a constiutionial procedure to pay owners for land to be used for a public purpose, a park” are even less entitled to relief.

  6. ” . . . 25 of the 30 lots condemned for this project were owned by whites.”

    And we are only going to address two of those lots, based on skin color. What a racist action.
    BTW, how much is owed in back property taxes?

    1. Yeah there was some racist action… “The Bruces and their customers were harassed and threatened by their white neighbors, including the Ku Klux Klan, the county board of supervisors said in a news release.”

      Oh wait, you’re not worried about that racist action.

      1. That literally doesn’t change anything. If compensation is being given for unjust taking, everyone who was the victim of it gets compensation.

        1. It suggests they faced pressures the other’s did not.

          1. “Suggests”. The weasel word of the dishonest

            30 property owners lost their property. They all were equally harmed, and it would take a truly “race” obsessed bigot to claim otherwise

          2. According to Prof. Somin, “25 of the 30 lots condemned for this project were owned by whites.”

            Hmm…30 lots minus 25 owned by whites equals 5 owned by non-whites. Yet only one is receiving restitution. I wonder why. Did the “white neighbors, including the Ku Klux Klan” not notice the four others?

            1. Why do you assume it’s one owner per lot? Couldn’t one owner own more than one lot?

          3. “It suggests they faced pressures the other’s did not.”

            Which is irrelevant — the Klan did not get title to the property, the city did. Just like it did with the White neighbors.

  7. In my view, takings for projects that never get built violate the constitutional requirement (embedded in both the Fifth Amendment of the Federal Constitution and similar clauses in virtually every state constitution) that eminent domain can only be employed for a “public use.” There can be no “public use” where the supposed purpose of the taking was never carried out, and especially not if this failure is predictable at the time of the taking.

    This doesn’t seem too practical to me. Judgments about whether a project is likely to be completed are never going to be clearcut.

    IMO the best solution is twofold.

    First, use eminent domain rarely, and only in clearcut public use cases.

    Second, pay “just compensation,” like it says. Not fair market value, or what some assessor thinks it’s worth, but an amount that makes the owners as well off (at least), including subjective values, as they were.

    1. Agree wholeheartedly, eminent domain is at *best* a necessary evil, it should be rare.

    2. The problem is that your definition of “just compensation” is so subjective that the standard can never be tested or adequately fulfilled. Put yourself in the shoes of a mayor using eminent domain to build a fire house (which for the sake of argument as to be built right there). What is “just compensation”? The average $35,000 that the other lots in the neighborhood sold for over the past year? The $3.5 million that the owner demands (maybe because she really attaches that much sentimental value to the land but also maybe because she too knows that the fire house must be built right there)? Something else? And why that price?

      I strongly agree that eminent domain should be used only rarely and in the most clearcut of cases. I don’t think you’ve got a good definition for “just compensation”, though.

      1. My understanding is that “just compensation” refers to the fair market value of the land being seized assuming it was being sold to another private party and assuming no governmental interest in the land.

        1. That is the traditional definition – which bernard11 explicitly rejected. I’m trying to figure out what he thinks counts as “just” instead.

          1. It’s a tricky problem, no doubt.

            But consider these possibilities.

            1. I like where I live where I live because I have a short commute to my job.

            2. I’ve lived here a long time, and am familiar with the neighborhood, local merchants, etc., plus I have friends who live nearby.

            3. My kids have friends in the neighborhood.

            4. My parents live a block or two from me.

            etc.

            Putting it in pure economic terms, FMV is where the supply curve and the demand curve intersect. But there is no reason to think that a given property owner is at or below that point. It is perfectly rational to assign one’s property a value greater than FMV.

            1. I hear you.
              If the city government wanted my home, I would not consider the FMV just compensation. But if they offered my 2 times the FMV. I’d take it.
              The point of just compensation for the Sturm and Drang of moving me at my great age would say the just compensation for the property and all of the troubles and expenses of moving for me would be a factor of two

            2. Yeah, I can’t remember the economic term for that, but it’s a real thing.

              If you have a non-fungible item, like a house or a painting or something, you probably value it at more than FMV.

              FMV is what somebody else would pay for it, but given that you haven’t sold it, and that values of a non-fungible item probably lie on a bell curve, it’s basically certain that you value it at least FMV – transaction costs, and likely that you value it more than FMV.

        2. I think the courts have defined it that way.

          That doesn’t make it an accurate definition, especially with regard to one’s home, or a small business one operates.

      2. 1: It’s never the case that it absolutely, positively, has to be built “right there”.

        2: Define what you need. “We need this much space, with this road access, in this area”. Allow everyone in the area who’s willing to sell to submit private bids (IOW, the city won’t release any of the bids until the bidding is closed). Allow neighbors to submit bids together if their lots are too small.

        Lowest bid gets bought, for the 2nd lowest bid’s price (this encourages people to bid their actual “I’d be happy if my bid were accepted” price).

        If no one in the area is willing to sell for a price you’re willing to pay, then I guess the project isn’t worth it

    3. Interesting question involves abandoned railroads. Many of the PennCentrals were bought up by utility companies and are now quite valuable with the lines being able to be put underground. Others people want to make into bike trails.

    4. Second, pay “just compensation,” like it says. Not fair market value, or what some assessor thinks it’s worth, but an amount that makes the owners as well off (at least), including subjective values, as they were.

      The issue here is that the literally only way to find the price that can be assured of making the owners as well off in subjective value is to find the price that they’re willing to voluntarily sell at. At which point you simply are saying, “abolish eminent domain”.

  8. I am sympathetic to this argument, however … what exactly is the procedure for proving its for a public use?

    A government siezes land to build a park. The landowner is compensated, but forcibly removed. The park never gets built. Government bulldozes land. Landowner says, aha, constitutional violation, and the government shrugs and says, whatever. The land is mine now. You already have been compensated. What is done is done, you don’t have standing to bring a suit, even if you did soverign immunity.

    There is nothing to enjoin here right? I suppose the government can give back the land … but the land is worthless now. And if the government sold it … are we going to force that third party to give it up?

    Eminent domain is stupid and ought to be restricted … but the court was trying to avoid. in Kelo, exactly this problem, and … idk you aren’t proposing a solution.

    1. You have no place in the party of Trump. And Rubio actually passed a law restricting use of eminent domain in Florida and it was a total disaster and Republican voters give him no credit for it anyway.

    2. “Eminent domain is stupid”

      Why? Its often the only way to get a needed road or police station built.

      1. Or obsolete ballpark! 😉

  9. What would be the injury to the original property owner?

    If the state used eminent domain to acquire my grandmother’s farm and provided the appraised value of $500,000, what difference would it make to us if the property was used for a highway or sat vacant?

    Certainly, it would be a waste of the taxpayer’s money, which is a distinct issue, but it does not change in any way the $100,000 I would get if it was use for a highway, sat vacant, or was sold by us to a developer.

    1. It matters because the Constitution requires both just compensation (the $100k) and that the taking be for “public use”. Taking something just to take it is wrong even if they pay you for it.

      The “public use” requirement solves (or at least, mitigates) the moral hazard and mitigates some of the resentment of the compelled sale. I may not like giving up my home but I can accept it better when it’s going for something that benefits the community (including me) like a hospital or a road. In other words, I get the $100k plus my share of the value of the future use. If it sits vacant, then all I get is the $100k. Not only is it a waste to the taxpayer but since I am also a taxpayer, I am actually worse off than if there had been no taking even if I am “justly compensated”.

      1. Sure, but let’s say you take it for public use and don’t actually use it for that purpose. What exactly is the remedy here? There is no injury. Its a requirement, but it is not a requirement that is at all feasible to reasonably enforce.

        Or say you have a non-traditional taking, where you don’t actually enter eminent domain proceedings you accidentally destroy someone’s house or its a regulatory taking or something. That is not for public use in any sense of the word. So what to do? You could say those aren’t takings, but I dont thing property rights people want to go down that road.

      2. That, however, does not mean the property owner suffered an actual injury.

        Otherwise, you end up with the Trump election lawsuits that one state’s putative violation of their own election laws somehow harmed another person in another state.

        If property was not taken for a public use, that would violate the Constitution, but that does not necessarily mean the original property owner suffered a concrete injury. The two are separate.

    2. “What would be the injury to the original property owner?”

      The injury is that they didn’t want to sell at that price, which is why the government “took” it instead of buying it.

      All government takings inflict an injury on the people they’re taking from. That’s the nature of the beast

      That’s why it has to be for “public use”. The assumption is that the benefit to “the public” is greater than the harm to the person whose property was taken.

      But there’s always a harm, which is why it should be rarely done

  10. Should seizure in eminent domain be compensated with the current market value or with the future use market value?

    1. The current market value already factors in an assessment of the land’s future value, appropriately discounted for the time it will take to become worth that much.

  11. If the city does return it, will the family have to return the money the city gave them “fair value” (by force) for the land? Adjusted for inflation, that would still be a lot of money.

    Would the family have to pay the city “fair value” in something like a reverse eminent domain?

    1. This case doesn’t involve ‘fair value’. That’s the whole point. The family were not originally compensated fairly, they were screwed over. A fairly cheap bit of land with a very lucrative business on it was taken for the value of the land. The business was wiped out without compensation.

  12. Judge Kozinski is the only lawyer smarter than Volokh, until that Brazilian kid came along. He persuaded me Kelo was a good decision.

    When a property is seized for a public highway, who will use the highway? It will be for profit truck companies. No difference from Kelo.

  13. Why isn’t this reverse discrimination considering the 25 lots owned by whites are getting nothing? Do their descendants have a case to go after those lots, once this action for the Bruce’s is complete and settled?

    1. There’s no such thing as “reverse discrimination”

      There’s just racism and discrimination. Who your targeting has nothing to do with right or wrong, it’s just about whose ox is getting gored

  14. Also, what about the following:

    There are cases of takings where it is not at all clear there is a use here. You nationalize a corporation. You accidentally bomb a neighborhood. That is a taking … but it isnt clear what the use was. It was an accident. Supposedly.

    Under the current regime, if the government passes a law that makes your land useless, you can call that a taking and demand compensation. Lets say Kelo is overruled. The government can only take private property for public use.

    Doesn’t that narrow the definition of taking itself? Say the government accidentally bombed your house. Its solely a question of remedies … there was no court order to bomb your house. It was an accident. Right now I the property owner can say you took my house, and seek compensation under the Tucker act and the 5th amendment.

    But add the public use requirement … the government will say this: There is no possible way to bomb your house and that being for public use. Again, it was an accident. There, even though your property lose all value, it cannot be a taking. You have a tort claim instead. But those are forbidden by soverign immunity, go away, do not pass go, do not collect damages.

    Or say in the case now forcing farm owners to grant an easement to unions is … there is zero conceivable way there is a public use there. So either the government can’t pass such a law, which, ok, fine, but with regulatory takings, that means the government can’t pass any regulation. Because it might be a taking, and there is no public use there so you can’t even compensate the owner. You might like that outcome, I might favor it, but surely that isn’t what the fifth amendment means.

    There more likely option is a dramatic narrowing of property rights under the fifth amednment, which is concerning. I dont like Kelo, but it seems any other outcome will necessarily limit the 5th amendment solely to eminent domain cases, which is deeply problematic.

    1. Any law you make is by definition for a public benefit. If you demand that people give union organizers access to their property, that is for the public good as *you* define it. Therefore our options are (1) you can’t do that, or (2) you can do it, but you must give just compensation. Libertarians would prefer the former, but the constitution chose the latter.

      Accidentally bombing someone’s property is the same: Whatever you did that led to the accident, you intended for the public good. Whether the public actually benefited is irrelevant; you did it for their benefit. Therefore it’s a taking, and since it’s already been done and can’t be reversed both Libertarians and the framers agree that compensation is the only option available.

      Oh, and the question of what compensation should be given for an unjust taking? The opportunity to buy it back at the same price and in the same condition (or for a lower price if it will cost money to put it back in the same condition).

  15. “if history had taken a different, more just, course, these particular descendants probably would never have been born” — wouldn’t this apply to _any_ compensation for past wrongs? In a counterfactual world where the person hadn’t been wronged, they could’ve died by now, could’ve lost the money in a market crash, etc.

  16. “Perhaps that is true. But, if history had taken a different, more just, course, these particular descendants probably would never have been born in the first place. Even a slight change in the course of events is enough to prevent a particular sperm and egg form meeting at a given time, and therefore prevent the birth of a specific person. The Bruce family might well still have descendants in this counterfactual world. But they would almost certainly be different people from those that exist in our world, today”

    Christopher Columbus to the white courtesy phone please. What would be the state of the New World be if CC had become a priest instead of sailing the ocean blue? I would argue, in terms of the native inhabitants, that it would be almost exactly the way it is now. No stone age culture, which the Western Hemisphere was exclusively populated by in 1492, would have long stood against Europeans of whatever stripe. Just their susceptibility to the diseases they were unintentionally infected with by explorers condemned 7/8s of the natives to extinction.

    1. “Just their susceptibility to the diseases they were unintentionally infected with by explorers condemned 7/8s of the natives to extinction.”

      The converse is also true, albeit to a lesser extent. Remember that almost half of the Pilgrims died the first winter. 17th Century settlers expected to have what they described as “New World Sickness” shortly after arrival here — and Columbus took Syphilis back to Italy with him.

  17. But, if history had taken a different, more just, course, these particular descendants probably would never have been born in the first place. Even a slight change in the course of events is enough to prevent a particular sperm and egg form meeting at a given time, and therefore prevent the birth of a specific person.

    This is the problem with time travel stories and the butterfly effect. A single molecule, disturbed in the slightest, eventually migrates up to a different weather pattern a few months down the road, then sex is happening at different times, different sperm are meeting different eggs (or even the same eggs), and in short order, a completely different generation has been swapped in.

  18. It really seems like the fairest thing would be for the City to return all the land it seized in eminent domain, both to the other black families and the other white families.

    On the other hand, I guess the Bruce family is the one that has been fighting this the hardest, and from the comments on the history article, it’s alleged that after they put up the largest fight against the eminent domain, they were blackballed out of buying other property in town.

    https://easyreadernews.com/sandbox-should-white-families-who-owned-25-of-the-30-bruces-beach-lots-in-manhattan-beach-also-receive-reparation/

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