The city of New York terminated its lease with the owner of a ten-acre piece of land to use for the city's own purposes. The city had leased the land to the owner when it was a forest (or other) preserve. The land was later converted into a residential community. The city claimed that the land was not properly zoned because the area had not been deeded as a park. The owner countered by calling the city's action a nullification of the land grant deed, and filed suit to recover his purchase price. The Supreme Court ruled that āThe deed conveyed to the State is an instrument not subject to change by the recipient, even though the land itself may, by the circumstances, be affected.ā While the city's action was void as an exercise of the public powers of eminent domain, it was not a nullification of the land grant deed.
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