BRADLEY v. United States

CourtUnited States Court of Federal Claims
DecidedDecember 17, 2025
Docket19-400
StatusPublished

This text of BRADLEY v. United States (BRADLEY 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.

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BRADLEY v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 19-400 Filed: December 17, 2025

ELIZABETH G. BRADLEY, et al.,

Plaintiffs,

v.

THE UNITED STATES,

Defendant.

Lindsay S.C. Brinton, Meghan S. Largent, and Michael Armstrong, Lewis Rice LLC, St. Louis, Missouri, for Plaintiffs.

David Harrington, Assistant Chief, Jennifer Sundook, Trial Attorney, Natural Resources Section, with Adam R.F. Gustafson, Acting Assistant Attorney General, Environment & Natural Resources Division, U.S. Department of Justice, Washington, D.C., for Defendant.

MEMORANDUM OPINION AND ORDER

TAPP, Judge. 1

Even as the path to finality winds through appellate terrain, the law permits a measure of recompense for steps already taken. After over six years of litigation in this rails-to-trails action, two groups of claimants now move for attorneys’ fees and related litigation expenses. (Pls.’ Mot., ECF No. 190 (citing Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (“URA”), 42 U.S.C. § 4654(c))). The first group received favorable judgments on liability and previous URA fees; the second group has received a favorable judgment—now appealed—as to liability and reached an agreement on just compensation alone.

As to the first group, the claimants have no active claims before this Court, and their right to compensation for appellate fees exhausted thirty days after judgment was final. Because the right to additional URA fees was not properly preserved, they may not be revived at this stage. Concerning the second group, though the liability determination is currently pending before the Federal Circuit, this Court retains jurisdiction to adjudicate the pending fee application. The United States has not raised a substantive objection regarding those fees, and the Motion is

1 The case was originally assigned to Senior Judge Margaret M. Sweeney and transferred to the undersigned on July 2, 2024. (ECF No. 151). References made to opinions issued prior to that date were issued by Judge Sweeney. otherwise well-founded as to that group. Accordingly, the Court GRANTS-IN-PART and DENIES-IN-PART Plaintiffs’ Motion. 2 Plaintiffs shall edit and submit a renewed fee request in conformance with the direction in the conclusion of this Opinion.

I. Background

Plaintiffs initiated this action on March 15, 2019, alleging a Fifth Amendment taking arising from the conversion of a 20.87-mile rail corridor near Indianapolis. (Compl., ECF No. 1). The case follows the Surface Transportation Board’s (“STB”) issuance of a Notice of Interim Trail Use (“NITU”) on December 20, 2018, which, according to Plaintiffs, resulted in the loss of “their right to unencumbered title and exclusive possession of their land.” (Id. at 14). The case initially involved fifteen landowners but later expanded to twenty-five. (Am. Compl., ECF No. 12; Sec. Am. Compl., ECF No. 42).

The early stages of this case were marked by optimism, as the parties found common ground on discovery practices. Following the filing of the Joint Preliminary Status Report, the parties agreed to proceed through a claims book process, which ultimately lasted nearly eleven months. 3 (ECF Nos. 8, 15, 21, 33). That process revealed title issues requiring further inspection and clarification. (ECF Nos. 15, 21, 33). The parties stipulated to title matters on some claims, but disagreements remained. (ECF No. 37). At that juncture, Plaintiffs proposed bifurcating litigation to allow valuation discovery for some plaintiffs while resolving liability for others. (Id.) The United States, by contrast, advocated for resolving each individual plaintiff’s title issue before proceeding to a collective valuation. (Id. at 4). A subtle precursor to the legal posture that ultimately emerged, these differing approaches marked the beginning of a series of procedural disagreements on case management.

The Court subsequently ordered summary judgment briefing on the unresolved title issues and stayed valuation discovery. (ECF No. 38). On Plaintiffs’ motion, the Court widened the scope of briefing to address new information provided by a prior landowner along the corridor, which necessitated the filing of another amended complaint. (ECF Nos. 40, 42, 44). Given the title issues arising for a subset of claimants—specifically concerning the prior execution of a “release” and its potential applicability across multiple cases—Plaintiffs moved for entry of a new and enlarged scheduling order pending possible certification of related questions to the Indiana Supreme Court. (ECF No. 46). In connection with that request, Plaintiffs

2 Implementation of that judgment will be stayed pursuant to RCFC 62, pending resolution of the appeal on liability. 3 In this Court, the term “claims book” is commonly used to refer to a plaintiff’s initial disclosures, which are typically provided to the United States before the RCFC 26 deadline. See Pressly v. United States, No. 18-1964, 2025 WL 1780947, at *1 n.5 (Fed. Cl. May 12, 2025) (listing disclosures to include deeds or other ownership documentation, tax records demonstrating ownership at the NITU date, valuation maps and schedules for the affected railroad corridor, original railroad conveyances, and maps showing the corridor’s location relative to each plaintiff’s property and the original conveyances).

2 also sought to set aside the existing summary judgment briefing schedule, expressing concern that no group should “wait on the other to catch up.” (ECF No. 46 at 3). The Court stayed summary judgment briefing to allow resolution of the certification issue. (ECF No. 47).

In July of 2020, the Court denied certification to the Indiana Supreme Court, and litigation reached a consequential turning point that resulted in piecemeal proceedings across segmented plaintiff groups. (Order on Groups’ Litig. Sched., ECF No. 52). These developments unfolded amid ongoing disputes involving the Indiana rail corridor, which continues to be implicated in indirectly related matters. 4 (Id.). The claimants in each of these cases were broken into three groups: “Group 1,” plaintiffs that had claims with no outstanding liability issues and could proceed to valuation calculations (“Group 1 Plaintiffs”); “Group 2,” plaintiffs that had claims that required the resolution of an essentially identical threshold title issue related to the “release” (“Group 2 Plaintiffs”); and “Group 3,” plaintiffs that had claims with other threshold title issues (“Group 3 Plaintiffs”). (See id.); Bradley v. United States, 164 Fed. Cl. 236, 244 (2023), appeal dismissed, No. 2023-1707, 2023 WL 4930847 (Fed. Cir. Aug. 2, 2023). Group 1 Plaintiffs moved on to a collective valuation process, Group 2 was set on a path for summary judgment, and Group 3 remained in discovery to settle title determinations. (Order on Groups’ Litig. Sched. at 7–10).

At the Court’s direction, Plaintiffs identified the group assignment for each individual plaintiff on August 6, 2020. (ECF No. 53). The next notable movement was the Court’s Summary Judgment Opinion dismissing the claims of Group 2 Plaintiffs. 5 (ECF No. 63 (withdrawn and superseded by ECF No. 78)). After that Opinion was issued on March 23, 2021,

4 See e.g., Oldham v. United States, No. 18-1961 (consolidated with Overlook At The Fairgrounds LP v. United States, No. 18-1962); Pressly v United States, No. 18-1964 (consolidated with Jones v. United States, No. 19-1375); Bradley v. United States, No. 19-400; Doyle v. United States, No. 19-882; Great Commission Church of God v. United States, No. 22- 1597; Best Access Solutions v. United States, No. 22-1598; 4624 N. Keystone Ave., LLC v. United States, No. 24-2037.

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