Justia Transportation Law Opinion Summaries

Two businesses operating an industrial warehouse and distribution center in Bonner Springs, Kansas, were affected by an ordinance enacted by the neighboring City of Edwardsville. This ordinance prohibited vehicles weighing over six tons from traveling on 110th Street—the street dividing the two cities—unless the trucks were entering or exiting Edwardsville. As a result, heavy trucks serving the businesses could not access 110th Street to enter or exit their properties. In response, the businesses filed suit against Edwardsville and certain city officials, alleging violations of federal and state law and seeking a preliminary injunction to prevent enforcement of the ordinance.The United States District Court for the District of Kansas dismissed the plaintiffs’ federal claims, including those under the Surface Transportation Assistance Act, the Equal Protection Clause, and the Dormant Commerce Clause, and denied the request for a preliminary injunction. However, the district court declined to dismiss the remaining state-law claims, leaving them pending.While the appeal was pending before the United States Court of Appeals for the Tenth Circuit, Edwardsville repealed the challenged ordinance and replaced it with a new one. The new ordinance allowed southbound trucks to enter the businesses from 110th Street, though certain restrictions remained. The Tenth Circuit determined that the repeal and replacement of the ordinance rendered the appeal moot because the controversy over the original ordinance no longer existed. The court found no exception to mootness applied and declined to vacate the district court’s order or exercise pendent appellate jurisdiction over the dismissed claims. Accordingly, the Tenth Circuit dismissed the appeal for lack of jurisdiction. View "Scannell Properties #516 v. City of Edwardsville, Kansas" on Justia Law

Five individuals residing near a New Orleans hospital brought suit after the hospital moved its helicopter landing pad from a one-story building near the Mississippi River to the top of a new tower in the center of the hospital complex. The plaintiffs, claiming that the new helipad created excessive noise and vibrations, sought a mandatory injunction requiring the hospital to relocate the helipad or otherwise abate the disturbance, as well as damages for nuisance and negligence.The defendants removed the case from state court to the United States District Court for the Eastern District of Louisiana. The district court denied the plaintiffs’ request to remand the case to state court, finding that their subsequent removal of class-action allegations and request to decline supplemental jurisdiction amounted to improper forum shopping. The district court then granted the defendants partial summary judgment, holding that Federal Aviation Administration regulations preempted any permanent injunction to relocate the helipad. The court also dismissed some of the plaintiffs’ claims for damages, but allowed their claims for general nuisance damages to proceed to trial. Before trial, the plaintiffs appealed the order, seeking review of the denial of their request for an injunction.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that it lacked jurisdiction over the interlocutory appeal because the district court’s order did not explicitly deny an injunction and, even if it had the practical effect of denying injunctive relief, the plaintiffs did not show that they satisfied the requirements for interlocutory review under 28 U.S.C. § 1292(a)(1) and Carson v. American Brands, Inc. The appeal was dismissed for lack of jurisdiction. View "Rey v. LCMC Health Care Partners" on Justia Law

A railroad company operating in Massachusetts sought to acquire a 155-acre parcel in the town of Hopedale to build a new transloading facility. The land had been classified as forest land under Massachusetts General Law Chapter 61, which gives municipalities a right of first refusal to purchase such land if the owner wishes to sell or convert it to another use. After an initial notice of intent to sell was deemed deficient by the town, the seller withdrew the notice. Without issuing a new notice, the seller then transferred beneficial ownership of the property to the railroad company through a transaction that attempted to circumvent the town’s rights. Hopedale asserted its rights under Chapter 61 and filed suit in Massachusetts Land Court to enforce its right of first refusal and prevent further site work by the railroad.After a failed settlement agreement—subsequently invalidated by the Massachusetts Superior Court and with state litigation ongoing—the railroad company petitioned the Surface Transportation Board for a declaratory order that the Interstate Commerce Commission Termination Act (ICCTA) preempted the town’s rights under Chapter 61. The Surface Transportation Board denied the petition, finding that Chapter 61 was a generally applicable property law not categorically preempted by ICCTA, and that the railroad had not established a valid property interest in the land. The Board also concluded that the town’s actions did not unreasonably burden or interfere with rail transportation.The United States Court of Appeals for the District of Columbia Circuit reviewed the Board’s order. It held that ICCTA does not preempt Chapter 61’s right-of-first-refusal provisions, as they are generally applicable state property laws and do not directly regulate railroad operations. The court further found that, without a settled property interest, the railroad’s as-applied preemption arguments failed. The court denied the railroad’s petition for review and affirmed the Board’s order. View "Grafton & Upton Railroad Company v. Surface Transportation Board" on Justia Law

A property development company sought to build mixed-use housing developments near a public-use airport operated by the City of Longmont, Colorado. The proposed developments were located under the airport’s approach and departure paths. The company received preliminary approvals from the City for its projects and obtained “Determinations of No Hazard” from the Federal Aviation Administration (FAA), which found the developments would not obstruct flight paths. However, the FAA sent letters to the City warning that approving the developments would violate a grant assurance tied to the airport’s federal funding, specifically regarding land use compatibility. The City subsequently denied the company’s proposal, citing multiple reasons, including the FAA’s letters, concerns from state authorities, its own findings of incompatibility, and public opposition.After the City’s decision, the developer asked the FAA to withdraw its letters, but the FAA declined. The company then petitioned the United States Court of Appeals for the District of Columbia Circuit to order the FAA to vacate and withdraw these letters, arguing that the FAA’s actions directly caused its injury by influencing the City’s denial.The D.C. Circuit dismissed the petition for lack of standing. The court held that the developer failed to demonstrate that vacating the FAA’s letters would likely result in the City approving the developments, as the City had provided multiple independent reasons for its denial beyond the FAA’s communications. The court also found that the company did not comply with the court’s procedural rule requiring petitioners to argue and provide evidence of standing in their opening brief. Accordingly, the petition was dismissed. View "ModernWest Longmont, LLC v. FAA" on Justia Law

Mendocino Railway, a California railroad corporation, sought to acquire a 20-acre parcel in Willits, California owned by John Meyer through eminent domain. The property is adjacent to Mendocino Railway’s tracks and was intended for the construction and maintenance of rail facilities supporting ongoing and future freight and passenger operations. The company argued that, as a common carrier public utility under relevant statutes, it had the authority to exercise eminent domain for public use. The evidence at trial included testimony about the history of rail service on the line, Mendocino Railway’s acquisition and operations, including passenger excursions and more limited commuter and freight services, and the necessity of the property for expanding its rail facilities.The Mendocino County Superior Court conducted a bench trial and found that Mendocino Railway failed to qualify as a public utility entitled to exercise eminent domain. The court reasoned that the railway’s primary activity was excursion service, which does not confer public utility status, and was unconvinced by the evidence of passenger and freight services. The court further concluded that, even if Mendocino Railway had public utility status, it did not meet the statutory requirements for eminent domain, finding the primary purpose of the proposed taking to be for private business activities rather than public use. The court also found insufficient evidence regarding the project’s impacts on neighboring residents and questioned the credibility and timing of Mendocino Railway’s site plans.On appeal, the California Court of Appeal, First Appellate District, Division One, reversed the trial court’s judgment. The appellate court held that Mendocino Railway met its burden of proving it was a common carrier public utility under California law, and that it satisfied the statutory requirements for eminent domain: public interest and necessity, proper planning for public good and least private injury, and necessity of the property for the project. The court remanded the case for further proceedings regarding compensation to Meyer. View "Mendocino Railway v. Meyer" on Justia Law

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