Phillips v. Washington Legal Foundation, 524 U.S. 156, 22 (1998)

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Cite as: 524 U. S. 156 (1998)

Souter, J., dissenting

the unchallenged federal and state regulations, raises serious questions about entitlement to any compensation (which, if required, would convert any "taking" into a wash transaction from the client's standpoint). "Just compensation" generally means "the full monetary equivalent of the property taken." United States v. Reynolds, 397 U. S. 14, 16 (1970). In determining the amount of just compensation for a taking, a court seeks to place a claimant " 'in as good a position pecuniarily as if his property had not been taken.' " United States v. 564.54 Acres of Monroe and Pike County Land, 441 U. S. 506, 510 (1979) (quoting Olson v. United States, 292 U. S. 246, 255 (1934)), calculating any loss objectively and independently of the claimant's subjective valuation, see, e. g., Kimball Laundry Co. v. United States, 338 U. S. 1, 5 (1949).

Thus, in deciding what award would be needed to place the client respondent in as good a position as he would have enjoyed without a taking, a court presumably would look to the claimant's putative property interest as it was or would have been enjoyed in the absence of IOLTA, cf. Boston Chamber of Commerce v. Boston, 217 U. S. 189, 195 (1910), and consequently would measure any required compensation by the claimant's loss, not by the government's (or the public's) gain, ibid. This rule would not obviously produce much benefit to respondents. While it has been suggested in their favor that a cognizable taking may occur even when value has been enhanced, on the supposed authority of Loretto, supra, at 437, n. 15, that case dealt only with physical occupation, it rested on no finding that value had actually been enhanced, and it held nothing about the legal consequences of an actual finding that enhancement had occurred. The Court today makes a further suggestion of a way in which respondents might deflect the objection that they have lost nothing, when it observes that the notion of property is not limited by the concept of value, ante, at 170. But the Court makes the point by equating the government's seizure

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