Justia Transportation Law Opinion Summaries

A joint drainage district, managed by the boards of supervisors for Floyd and Cerro Gordo Counties, sought to require a railroad company to install a new, larger drainage culvert through a railroad embankment to improve water flow and address aging infrastructure. The existing culvert, over a century old, was deteriorating and positioned too high to drain water effectively. The proposed construction involved a trenchless “jack and bore” method designed to avoid any interruption to rail service. The railroad company objected, arguing that federal law preempted state drainage law and that the construction would jeopardize railroad operations.After a remand from the Surface Transportation Board, the Iowa District Court for Floyd County conducted a bench trial and concluded that federal law—the Interstate Commerce Commission Termination Act—preempted the drainage district’s authority. The district court found that the proposed installation posed risks to rail operations and issued a writ of mandamus preventing the project. The Iowa Court of Appeals affirmed this decision.On further review, the Iowa Supreme Court held that the federal statute did not categorically preempt state drainage law in this context and that preemption would only apply if the project imposed more than incidental interference with rail operations. After a de novo review of the evidence, the court determined that the proposed culvert installation would have only incidental effects on rail transportation and that the railroad had not met its burden of showing unreasonable interference. The Iowa Supreme Court vacated the Court of Appeals’ decision, reversed the district court’s judgment, and remanded the case for entry of judgment in favor of the drainage district, dissolving the writ of mandamus. View "Iowa Northern Railway Company v. Floyd County Board of Supervisors" on Justia Law

Pedro Castaneda died in a traffic accident at an intersection on State Highway 249 that was under construction. At the time, the intersection’s traffic lights were installed but not yet operational, and there was a dispute about whether they were properly covered to indicate their status. Castaneda’s family sued the contractors involved in the project, SpawGlass Civil Construction, Inc. and Third Coast Services, LLC, alleging that negligence in the construction and installation of the traffic signals contributed to the fatal accident. The construction project was governed by an agreement between the Texas Department of Transportation (TxDOT) and Montgomery County, with the County responsible for the project’s design and construction, but with TxDOT retaining authority over the adjacent frontage roads and final approval of plans.The trial court denied the contractors’ motions for summary judgment that sought dismissal under Texas Civil Practice and Remedies Code Section 97.002, which grants immunity to contractors under certain conditions. The contractors appealed. The Fourteenth Court of Appeals affirmed, concluding that Section 97.002 applies only to contractors who are in direct contractual privity with TxDOT, and since neither contractor had a direct contract with TxDOT, they could not invoke the statute’s protection.The Supreme Court of Texas reversed the court of appeals. It held that Section 97.002 does not require direct contractual privity with TxDOT for a contractor to qualify for statutory immunity. The court determined that, based on the summary judgment record, SpawGlass and Third Coast performed work "for" TxDOT within the meaning of the statute, as their activities directly related to frontage roads that TxDOT would own and maintain. The court remanded the case to the court of appeals to determine whether the contractors met the remaining requirements of Section 97.002. View "THIRD COAST SERVICES, LLC v. CASTANEDA" on Justia Law

The case involves a dispute between the owners and operators of a tourist attraction, Bear World, and the Idaho Transportation Department (ITD) over the closure of an intersection on Highway 20 in Madison County, Idaho. Bear Crest Limited LLC owns parcels of land leased to Yellowstone Bear World Inc., and Michael Ferguson is associated with both entities. In 1973, the original landowners (the Gideons) conveyed land to ITD’s predecessor for highway expansion, reserving “Access to the County Road Connection.” In 2016, as part of a highway upgrade to controlled-access status, ITD closed the intersection nearest Bear World, requiring visitors to use a more circuitous route, increasing travel distance by about five miles.After the intersection closure, the plaintiffs sued ITD for breach of contract and inverse condemnation, arguing that the closure violated the reserved access right in the Gideon deed and constituted a taking of property without just compensation. Both parties moved for summary judgment. The District Court of the Seventh Judicial District, Madison County, granted summary judgment to ITD, finding that the deed did not guarantee access to Highway 20, only to a county road, and that the closure did not amount to a compensable taking since alternative access remained.On appeal, the Supreme Court of the State of Idaho reversed in part, vacated the district court’s judgment, and remanded. The Court held that Bear Crest Limited had standing and that the Gideon deed unambiguously reserved access to the specific Highway 20 connection, not merely to a county road. The Court found that ITD’s closure of the intersection breached the deed and substantially impaired Bear Crest’s access rights, constituting a taking under Idaho law. The Court directed entry of partial summary judgment for Bear Crest on both claims, reserving damages and other issues for further proceedings. View "Bear Crest Limited LLC v. State of idaho" on Justia Law

The Vermont Agency of Transportation (AOT) proposed a project to reconstruct the interchange between Interstate 89 and U.S. Routes 2 and 7 in Colchester, Vermont, into a Diverging Diamond Interchange (DDI). Timberlake Associates, LLP, the landowner of a gas station at the southeast corner of the interchange, contested the necessity of the land takings required for the project. Timberlake argued that AOT did not fulfill its pre-suit obligation to negotiate and that the trial court erred in its determination of necessity.The Superior Court, Chittenden Unit, Civil Division, held a four-day evidentiary hearing and concluded that Timberlake failed to demonstrate bad faith or abuse of discretion by AOT. The court found that AOT had satisfied its burden of demonstrating the necessity of taking Timberlake’s property to the extent proposed. Timberlake appealed the decision, arguing that AOT did not adequately consider the statutory factors of necessity and failed to negotiate in good faith.The Vermont Supreme Court reviewed the case and affirmed the lower court’s decision. The Court found that AOT presented sufficient evidence showing it considered the statutory factors, including the adequacy of other property and locations, the effect on the landowner’s convenience, and the environmental impacts. The Court also determined that AOT’s selection of the DDI design was justified based on its superior performance in increasing capacity, reducing congestion, and improving safety compared to other alternatives. Additionally, the Court concluded that AOT made reasonable efforts to negotiate with Timberlake before filing suit, as required by statute.The Vermont Supreme Court held that the trial court acted within its discretion in determining the necessity of the takings and that AOT fulfilled its pre-suit obligation to negotiate. The decision of the lower court was affirmed. View "Agency of Transportation v. Timberlake Associates, LLC" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment for the Orange County Transportation Authority (OCTA) in a case brought by two utilities, Southern California Edison Company and Southern California Gas Company. The utilities claimed they were entitled to compensation under the Takings Clause or under state law for having to relocate their equipment from public streets to allow for the construction of a streetcar line.The court held that the utilities did not have a property interest under California law in maintaining their facilities at their specific locations in the face of OCTA’s efforts to construct a streetcar line. The California Supreme Court recognized in a previous case that a public utility accepts franchise rights in public streets subject to an implied obligation to relocate its facilities therein at its own expense when necessary to make way for a proper governmental use of the streets.The court rejected the utilities’ argument that constructing rail lines is per se a proprietary activity, not a governmental one. California common law has traditionally required utilities to bear relocation costs when governments construct subways, and there is no reason why above-ground rail lines should be treated differently.Finally, the court rejected the utilities’ supplemental state-law claim that California Public Utilities Code section 40162 places the costs of relocation on OCTA. That provision says nothing about imposing the costs of relocation on OCTA. Thus, section 40162 does not apply to OCTA’s project. View "SOUTHERN CALIFORNIA EDISON COMPANY V. ORANGE COUNTY TRANSPORTATION AUTHORITY" on Justia Law

In this case, Norfolk Southern Railway Company and Dille Road Recycling, LLC disputed over a narrow parcel of land adjacent to Norfolk’s active rail line in Euclid, Ohio. Although Norfolk owned the land, Dille had been using it for nearly two decades. The parties took the matter to federal court after negotiations failed. Dille sought to claim the parcel through adverse possession or a prescriptive easement, while Norfolk argued that Dille’s property claims were preempted by the Interstate Commerce Commission Termination Act (ICCTA). The district court held that Dille’s prescriptive-easement claim was not preempted and granted Dille the easement.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision, ruling that federal law preempted Dille’s state-law prescriptive-easement claim. The court determined that the easement Dille sought was so exclusive and conflicting that it was essentially adverse possession by another name. The court noted that while Dille claimed the easement was nonexclusive, the reality was that Dille's use of the parcel did not allow for shared use with Norfolk. The court also found that Dille's proposed use of the parcel was much closer to the complete taking of the property, which would unreasonably interfere with rail transportation and therefore was preempted by the ICCTA. The court reasoned that the possession or conflicting use of railroad property can be burdensome even if the railroad is not currently using the contested property. The case was remanded for further proceedings consistent with the opinion. View "Norfolk Southern Railway Co. v. Dille Road Recycling, LLC" on Justia Law

The case involves a fatal accident that occurred at a private railroad crossing owned by Ezra Alderman Ranches, Inc. and operated by Union Pacific Railroad Company. Rolando Prado, Jr. died when his vehicle was struck by a Union Pacific train at the crossing. His family members (the Prados) sued both Union Pacific and Ezra Alderman Ranches, Inc. for negligence. The central issue before the Supreme Court of Texas was whether the evidence was sufficient to create a fact issue on whether the railroad crossing, which was protected by both a stop sign and a crossbuck sign, was "extra-hazardous" and whether the landowner knew it was "unreasonably dangerous."The court held that the evidence was insufficient to support a finding that the crossing was extra-hazardous. The court reasoned that the crossing had a stop sign in addition to the usual crossbuck sign, and anyone who actually stopped at the sign could clearly see a train coming from either direction. The expert testimony that suggested drivers would not stop at a particular stop sign because it "lacks credibility" did not establish that all reasonably prudent drivers would not, much less could not, stop at the sign.The court also held that there was no evidence to support a finding that the landowner, Ezra Alderman Ranches, Inc., had actual knowledge that the crossing was unreasonably dangerous. The court determined that the evidence indicated that the landowner knew of the high volume of traffic at the crossing, but it did not establish that the landowner had actual knowledge that the crossing was unreasonably dangerous.The court reversed the decision of the court of appeals and reinstated the judgment of the trial court in favor of Union Pacific and Ezra Alderman Ranches, Inc. View "UNION PACIFIC RAILROAD COMPANY v. PRADO" on Justia Law

The Supreme Court affirmed the judgment of the State Corporation Commission dismissing Verizon Virginia LLC's petition for a declaratory judgment for lack of subject matter jurisdiction, holding that the Commission lacked subject matter jurisdiction over Verizon's petition pursuant to Va. Code 33.2-1815(B) and 33.2-1821.Verizon, a telecommunications company, filed a petition for a declaratory judgment with the Commission requesting a declaration that either Capital Beltway Express LLC (CBE) or The Lane Construction Corporation was responsible for costs pursuant to section 33.2-1815(B) to relocate some of Verizon's utility facilities, as required by the Virginia Department of Transportation in the underlying project to extend portions of the I-495 express lanes. The Commission dismissed the petition for lack of jurisdiction. Verizon appealed, arguing that sections 33.2-1815(B) and 33.2-1821 granted the Commission jurisdiction to resolve which party was responsible for the costs of the utility relocations necessitated by the project. The Supreme Court affirmed, holding that the Commission correctly concluded that it lacked subject matter jurisdiction over Verizon's petition. View "Verizon Virginia LLC v. SCC" on Justia Law

In 1907, the then-owner executed the “Stimson deed,” transferring to the Railroad “its successors and assigns, the right to cross said right of way at any point or points where such crossing is desired” the land at issue. POTB later took ownership of the railroad. A 2007 storm caused severe damage to the railroad tracks. POTB did not repair the damage, resulting in the disbandment of the Oregon Tillamook Railroad Authority. POTB, with governmental entities, established the Salmonberry Trail Intergovernmental Agency, to construct “a new multi-use trail” that would “connect[] to a wide network of existing recreation[al] trails and parks, educational opportunities, and heritage sites” over portions of the railroad line. In 2016, POTB filed a notice of intent to abandon service of the portions of the railroad line at issue with the Surface Transportation Board, which issued a Notice of Interim Trail Use (NITU) allowing interim trail use and railbanking under the National Trails System Act Amendments, 16 U.S.C. 1247(d).The Claims Court and Federal Circuit rejected Stimson’s claim that the creation of the trail constituted a Fifth Amendment taking. Railbanking and interim trail use are within the scope of the easement. Stimson failed to show abandonment for all purposes and had no compensable property interest in the land to which the deed pertained. View "Stimson Lumber Co. v. United States" on Justia Law

The Supreme Court granted Relator's request for a writ of mandamus ordering the Ohio Department Transportation and its director (collectively, ODOT) to begin appropriation proceedings for the taking of real property owned by Relator, holding that appropriation proceedings were necessary.ODOT's roadway construction project resulted in Relator's property being inaccessible from any road. Relator filed this action seeking a writ of mandamus ordering ODOT to commence appropriation proceedings pursuant to Ohio Rev. Code 163. ODOT argued in response that Relator could obtain a permit from the city of Cleveland to connect the property to a road and that Relator must apply for and be denied such a permit before he was entitled to mandamus. The Supreme Court granted Relator's request for a writ of mandamus and ordered ODOT to commence appropriation proceedings, holding that Relator was entitled to a writ compelling ODOT to commence appropriation proceedings. View "State ex rel. Balunek v. Marchbanks" on Justia Law