BEEMAN v. United States

CourtUnited States Court of Federal Claims
DecidedMay 27, 2025
Docket21-1278
StatusPublished

This text of BEEMAN v. United States (BEEMAN v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BEEMAN v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims Nos. 21-1278; 22-1531 Filed: May 27, 2025 ________________________________________ ) ERIC BEEMAN, et al., ) ) ) Plaintiffs, )

) v. ) ) THE UNITED STATES, ) ) Defendant. ) ________________________________________ )

Meghan S. Largent, Lewis Rice LLC, St. Louis, MO for Plaintiffs, with whom were Lindsay S.C. Britton and Michael Armstrong, Lewis Rice LLC, St. Louis, MO.

Ashley M. Carter, Trial Attorney, United States Department of Justice, Environment & Natural Resources Division, Natural Resources Section, Washington, D.C., with whom was Todd Kim, Assistant Attorney General, United States Department of Justice, Environment & Natural Resources Division.

OPINION AND ORDER

MEYERS, Judge.

When rail provided much of this nation’s long-haul transportation, railroads often acquired easements over the land on which their lines ran rather than purchasing that land. As technology progressed, other means of transportation supplanted rail lines as the backbone of transportation. As a result, railroads began abandoning their unused lines, which led to a significant contraction of the country’s rail network because many easements ended upon the abandonment of rail use. To preserve the rail network for potential reactivation, Congress passed the Trails Act. That act provides that if an eligible trail operator comes forward and expresses its interest in maintaining the rail corridor as a recreational trail, the Surface Transportation Board (“STB”) could prevent the abandonment of the rail corridor by issuing a Notice of Interim Trail Use, or “NITU.”

It is now firmly established that when the STB issues a NITU pursuant to the Trails Act, a compensable taking often occurs. The taking results when the NITU blocks the extinguishment of the easement, thus taking from the plaintiff the unencumbered right to the land under the rail line. The taking becomes permanent if the railroad and trail use sponsor reach an agreement by which the sponsor takes over responsibility for the rail line to operate a recreational trail. These cases are so common that they have garnered their own nickname—the rails-to-trails cases.

This case, however, is one of a small number of cases in which the STB issued a NITU very late in the process, the railroad and potential trail operator did not reach a trail use agreement, and the railroad did not abandon the rail line. In fact, the railroad in this case is currently seeking authorization to begin running trains across the line again. Thus, this is perhaps better considered a “rails-to-rails” case in which the court must determine whether the NITU effected a temporary taking of the Plaintiffs’ property during the period it was in effect. To resolve this case, the court must determine whether and when the railroad would have abandoned the rail line but for the NITU. As a result of factual disputes between the Parties, the court cannot determine whether, much less when, the railroad would have abandoned the rail line at issue. The court, therefore, denies the cross-motions for summary judgment.

I. Background

The portion of the railway (“the Line”) at issue in this case sits in Allegany County, Maryland (“the County”). 1 ECF No. 8-1 at 10. The Eighteen Thirty Group and Georges Creek (collectively, “the railroad”) 2 obtained an easement to the Line and spent nearly a decade operating it. ECF No. 53-1 at 2; ECF No. 53-14. That changed in early 2020.

In accordance with the Trails Act, 16 U.S.C. § 1247(d), the railroad filed a Verified Notice of Exemption with the STB on February 3, 2020, requesting abandonment authority, and proposing consummation of abandonment on March 24, 2020. ECF No. 53-2 at 3, 5. 3 Abandonment would entail “removal of the rail, crossties, and possibly the upper layer of ballast.” 4 Id. at 19 (citing 49 C.F.R. §§ 1105.7–.8).

On February 21, 2020, the STB served notice of the exemption via publication in the Federal Register. ECF No. 53-3; see also Eighteen Thirty Group, LLC—Abandonment Exemption—in Allegany County, MD.; Georges Creek Railway—Discontinuance Exemption— in Allegany County, MD, 85 Fed. Reg. 10,203 (Feb. 21, 2020). This would give the railroad

1 The approximately 7.54-mile-long rail corridor is from “from milepost BAI 26.00 in Moscow, MD to 18.46 in Shaft, MD.” ECF No. 53-2 at 2. 2 Because the specific railroad that received the property is generally not material to the Parties’ dispute, the court refers to them as “the railroad” unless an issue depends on the specific railroad company. 3 The railroad could have filed a standard abandonment application. 49 U.S.C. § 10502. Because it filed a Notice of Exemption, it also certified that “[n]o local traffic has moved over the Line during the past two years” and that “[a]ny overhead traffic on the Line can be and has been rerouted.” ECF No. 53-2 at 9; 49 C.F.R. § 1152.50(b). 4 Ballast is “gravel or coarse stone used to form the bed of a railroad track or road.” Ballast, Merriam-Webster, https://www.merriam-webster.com/dictionary/ballast.

2 until February 20, 2021, to abandon the Line. 5 And on March 19, 2020, the STB granted the railroad’s request to abandon, effective March 22, 2020. ECF No. 53-4 at 2. To finalize the abandonment, the railroad merely had to file a notice of consummation with the STB “to signify that it has exercised the authority granted and fully abandoned” the Line. ECF No. 53-3 at 5 (citing 49 C.F.R. § 1152.29(e)(2)). Without such notice, and assuming there were “no legal or regulatory barriers to consummation,” abandonment authority would automatically expire. Id. When March 24, 2020, came around—the date the railroad indicated it would abandon the Line—the railroad had not filed a consummation notice, nor does it appear to have removed any rail or crossties from the Line. In other words, the Line had not been abandoned.

The process continued:

• On December 10, 2020, the County belatedly filed a request for the STB to issue a NITU for the Line. ECF No. 53-5 at 2. Although potential trail sponsors must request a NITU within ten days after the STB publishes the notice in the Federal Register, 49 C.F.R. § 1152.29, the County’s filing was approximately 290 days after the March 2, 2020 deadline. The Covid-19 pandemic apparently delayed the County’s internal processes. ECF No. 53-5 at 2–3 (explaining that “it has taken some time for the County to formally establish itself as the sponsor applicant for this trail,” because “of the time required to finalize a cooperative relationship with the Maryland Department of Natural Resources (“DNR”) . . . , and in part due to administrative delays caused by Covid-19 impacts”). • On January 5, 2021, the railroad agreed to negotiate for interim trail use. ECF No. 53-6 at 2. • On February 2, 2021, the County corrected its December 10 request after the STB informed it of a defect in the initial request to fully comply with regulations. 6 ECF No. 53-7 at 2. 7 • On February 18, 2021, the STB issued the NITU, granting the railroad and the County the right to negotiate for interim trail use until February 18, 2022. ECF No. 53-9 at 2.

5 The February 21, 2020 notice contained an error.

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BEEMAN v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beeman-v-united-states-uscfc-2025.