State of Indiana v. Franciscan Alliance, Inc.

Summary

The Indiana Supreme Court held that landowners cannot recover eminent-domain damages for increased travel distance or changed traffic flow when a roadway project leaves their existing ingress and egress points unchanged. Because the intersection closure did not affect either appellee's access points and the claimed damages arose solely from altered traffic flow, the damages were not compensable as a matter of law. The court reversed and remanded for determination of only the compensation owed for the condemned strip of land; the concurring justices filed no separate opinion.