Utah Dep’t of Transportation v. Boggess-Draper Co., LLC, 2020 UT 35 (June 11, 2020)

In this condemnation proceeding, the supreme court held that there is no categorical bar precluding admission of evidence of a post-valuation-date sale or development of property.  The admissibility of such evidence depends on the circumstances of the case and is to be determined under the Rules of Evidence.  The court also rejected the condemnee’s argument that “just compensation” includes the condemnee’s costs and attorney fees incurred in seeking fair market value.