City of Meridian v. New Orleans & Northeastern Railroad

291 F. Supp. 303, 1968 U.S. Dist. LEXIS 9252
CourtDistrict Court, S.D. Mississippi
DecidedAugust 2, 1968
DocketCiv. A. No. 1135
StatusPublished

This text of 291 F. Supp. 303 (City of Meridian v. New Orleans & Northeastern Railroad) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Meridian v. New Orleans & Northeastern Railroad, 291 F. Supp. 303, 1968 U.S. Dist. LEXIS 9252 (S.D. Miss. 1968).

Opinion

RUSSELL, District Judge.

OPINION OF THE COURT

The City of Meridian, Mississippi, originally filed this action in 1962 in the Chancery Court of Lauderdale County, Mississippi, against New Orleans and Northeastern Railroad Company, a foreign corporation doing business in the State of Mississippi, seeking mandatorily to require said defendant to remove five culverts installed under its trackbed which allegedly impede the flow of Gallagher Creek and cause it to overflow its banks during and following heavy rains. The cause was removed to this court on diversity of citizenship and a claim of $25,000.00 in damages. In 1963, plaintiff was granted leave to recast its original complaint. In 1965, plaintiff having declined to amend, defendant amended its answer and filed a counterclaim for declaratory relief denying that the cause presents a justiciable controversy. During the course of the trial, the presiding Judge died, and the case has been re-heard by this Court without a jury.

Although a great part of the evidence was couched in scientific terms by engineers and hydrologists, the issue is fairly simple. By installing five drainage culverts in what, before 1955, was an open trestle, has the defendant railroad materially contributed to the flooding of Gallagher Creek during periods of heavy rains, and, if so, does the plaintiff, City of Meridian, have the right to require the railroad to remove the culverts ?

Gallagher Creek is a five mile meandering, nonnavigable stream, running generally north to south within the city limits of Meridian. Toward its southern end, and about a mile north of where it runs into Sowashee Creek, the parallel tracks of the Illinois Central Railroad Company and of defendant railroad cross the creek bed in an easterly and westerly direction, the Illinois Central tracks lying north of those of defendant. During rains, Gallagher Creek drains surface waters from an area of 3500 acres along both banks, approximately 3400 acres of which are north of the tracks and in an urban area. Prior to 1955 all of the tracks were laid over an open, wooden type trestle, the underside of which was higher than the banks of the creek. In 1955, the defendant, at a point under the trestle where its tracks lie, installed five, corrugated metal pipes or culverts, each a little over eight feet in diameter, and offering a total opening of 276.25 square feet. These pipes, a couple of feet apart and 120 feet in length, with a 30 degree bend near their entrance, extend to the south side of the trestle. All of the area around the pipes, formerly open, was filled in and [305]*305now forms part of the railroad embankment. The City of Meridian not only owns property along the creek but has installed and maintains drainage structures or bridges at various points north of the trestle where city streets cross the stream, among them, going north from the trestle, crossings or bridges at Hooper St., 5th St., Paulding St., and 8th St. Both sides agree that prior to and since 1955, particularly in 1962 and 1964, flood waters have overflowed Gallagher’s banks at one or more of these points, including the area adjacent to the trestle on the north. Plaintiff, while conceding that its drainage structures at the above named streets do not at all times adequately carry the flow because of trash and other obstructions, utility lines which cross at these points, and silting, at the same time pointing out that excess water can and does freely flow over the utility lines, contends that the overflow and silting have been increased due to the inadequacy of defendant’s culverts below these crossings. On the other hand, defendant maintains that, first, its culverts are adequate to carry a reasonable flow, and, second, that the culverts are only a part of an over-all drainage problem arising from flooding of Gallagher Creek and Sowashee Creek to the southeast, which cannot be solved piece meal. Further, that the flooding occurring north of the trestle is caused by plaintiff’s inadequate structures and failure to keep the channel free of obstructions. To this plaintiff responds that if its structures were unimpeded, the greater would be the flood at the culverts.

The Court viewed the sites of the various drainage structures at a time when the flow through the creek bed was nothing more than a trickle. According to profile charts, the area of the bridge opening at Hooper St. is 336 square feet, at Fifth St. is 356 square feet, and at Paulding St. is 400 square feet. As stated above, the opening provided by the down stream railroad culverts is a total area of 276.25 square feet. The top of the trestle was established as 313 feet above mean sea level and six to seven feet above the tops of the culverts. At the time of the Court’s viewing, all of these openings were partially blocked by silt, tree limbs, trash and refuse. At the street openings, there were one or more water or other utility pipes laid from bank to bank, the degree of their impediment to a free flow being in dispute.

The 1962 and 1964 flooding of Gallagher Creek, following periods of heavy rains, were the focal points of most of the evidence. James L. Garrett, city engineer for plaintiff, among those who testified that flooding upstream was worse since the installation of the culverts, stated that the City had dredged the channel in 1959, and, due to the culverts, that silting, particularly from the trestle to Hooper Street, was more pronounced than prior to 1955. He observed both the 1962 and 1964 floods and saw water flowing over the city bridges, which the water could not do at the site of the culverts as their highest point is below the heighth of the embankment. In 1962, the highwater mark on the north side of the trestle was 307.-19 feet above mean sea level, and 304.63 feet above on the south side, the difference being the head loss attributable to the inadequacy of the culverts, and which head loss caused a slowing in velocity, backwater, and, consequentially, more silting and a raising of the channel bottom. He stated that there are a number of formulas for determining the adequacy of drainage installations, among them, Talbot’s formula used by the Mississippi State Highway Department. By use of this formula, he calculated that there should be an opening at the railroad embankment of 360 square feet instead of the actual area of 276.25 square feet.

Witness Allen G. Cox, representing a consulting engineering firm employed by plaintiff in 1963 to make a study of the Gallagher Creek drainage area, reviewed the conclusions of that study, saying that if all five railroad culverts were fully effective, they would be inadequate [306]*306to carry the volume of run-off based on periodic rain return frequencies, the head loss for a once in fifty year rain being 2.7 feet, and for a twenty-five year rain, 2.5 feet. Based on weather information and high water marks, he described the 1962 flood, in which the culverts were not fully effective and when there was a 2.5 foot head loss, as a minor storm, having a return frequency of two to five years. The report recommended that a drainage structure should be designed in urban areas to accommodate a flood of a fifty year return cycle at a flow of 2250 cubic feet per second, which in this instance should have a minimum opening of at least 350 square feet, preferably one bridge-type opening rather than numerous pipes. On cross-examination he conceded that the city’s drains at street crossings were not fully effective due to silting, but that these obstructions were negligible compared to that at the culverts.

By agreement of the parties, a hydrologist and a soil conservationist, employees of the U. S.

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Bluebook (online)
291 F. Supp. 303, 1968 U.S. Dist. LEXIS 9252, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-meridian-v-new-orleans-northeastern-railroad-mssd-1968.