Consolidated Rail Corporation v. City Council of the City of Jersey City

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 27, 2025
DocketA-1246-22
StatusUnpublished

This text of Consolidated Rail Corporation v. City Council of the City of Jersey City (Consolidated Rail Corporation v. City Council of the City of Jersey City) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consolidated Rail Corporation v. City Council of the City of Jersey City, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1246-22

CONSOLIDATED RAIL CORPORATION,

Plaintiff-Respondent,

v.

CITY COUNCIL OF THE CITY OF JERSEY CITY,

Defendant-Appellant,

and

JERSEY CITY PLANNING BOARD,

Defendant-Respondent. ____________________________

Argued March 11, 2024 – Decided March 27, 2025

Before Judges DeAlmeida, Berdote Byrne, and Bishop- Thompson.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-4542-21. Thomas J. Slattery, Assistant Corporation Counsel, argued the cause for appellant (Peter J. Baker, Corporation Counsel, attorney; Thomas J. Slattery, on the briefs).

Kevin J. Coakley argued the cause for respondent Consolidated Rail Corporation (Connell Foley LLP, attorneys; Kevin J. Coakley and Patrick J. McAuley, of counsel; Ryan A. Benson, on the brief).

Vincent J. La Paglia argued the cause for respondent Jersey City Planning Board.

The opinion of the court was delivered by

DeALMEIDA, J.A.D.

Defendant City Council of the City of Jersey City (the Council) appeals

from the November 16, 2022 judgment of the Law Division removing real

property owned by plaintiff Consolidated Rail Corporation (Conrail) from the

non-condemnation area in need of redevelopment (AINR) established by the

Council in Resolution No. 21-692 (Resolution). We affirm.

I.

Conrail is a rail carrier and owner of twenty-eight parcels in Jersey City

(the Property). 1 The parcels are contiguous with the active National Docks

1 The Property is designed in the tax record of Jersey City as Block 10901, Lots 92, 93, 108, 109, 111, 118, 120, 121, 122 and 123; Block 8401, Lots 2, 3, 8, 9, 10, 11, 13, 14, and 15; Block 6902, Lots 1, 2, 3, 4, 5, 8, and 35; and Block 9801, Lots 1 and 19. A-1246-22 2 freight rail line running north to south through the center of the Property. The

active railroad tracks are on some, but not all, of the parcels that comprise the

Property.

On February 10, 2021, the Council adopted Resolution No. 21-124

(Preliminary Resolution) directing defendant Jersey City Planning Board

(Board) to undertake a preliminary investigation to determine whether forty -

three lots (Sixth Street Embankment Study Area), which included the Property,

satisfied the statutory criteria in the Local Redevelopment and Housing Law,

N.J.S.A. 40A:12A-1 to -89, for designation as an AINR. The Preliminary

Resolution divided the Sixth Street Embankment Study Area into two groups:

(1) eight lots not owned by Conrail (Condemnation Study Area); and (2) the

remaining thirty-five lots, including the Property (Non-Condemnation Study

Area). The Council sought a determination from the Board of whether the lots

in the Condemnation Study Area should be designated as an AINR with the

power of eminent domain and the lots in the Non-Condemnation Study Area

should be designated as an AINR without the power of eminent domain.

In connection with the preliminary investigation, Timothy Krehel, the

City's Planner, prepared a report addressing the Non-Condemnation Study Area.

Krehel described most of the lots comprising the Property as vacant, but noted

A-1246-22 3 that an active freight line runs across seven of the lots. He characterized five of

the lots as "internal" and not having access to a street or a street address, but

being adjacent to active rail lines. The remaining lots were described as having

inactive rail infrastructure, including an inactive train trestle, or undeveloped,

with one lot being adjacent to an active rail line operated by the Port Authority

of New York and New Jersey. Of the parcels comprising the Property, one lot

borders Newark Avenue, one borders County Road 139, and four are crossed by

elevated spurs of the New Jersey Turnpike Extension.

Krehel's report concludes the Property and the other lots in the Non-

Condemnation Study Area qualify as an AINR under N.J.S.A. 40A:12A-5(c).

That statute authorizes the Council to declare a delineated area to be an AINR

if it is

unimproved vacant land that has remained so for a period of ten years prior to adoption of the resolution, and that by reason of its location, remoteness, lack of means of access to developed sections or portions of the municipality, or topography, or nature of the soil, is not likely to be developed through the instrumentality of private capital.

[N.J.S.A. 40A:12A-5(c).]

The report stated that except for the portions of the parcels on which the active

rail line is located, the Property has been vacant and unimproved for over ten

A-1246-22 4 years. The report also asserts that several lots in the Property "have access issues

due to their location, topography issues from proximity to the Palisades, and the

possibility of soil contamination issues."

Krehel's report also opines the Property qualifies as an AINR under

N.J.S.A. 40A:12A-5(h). That statute authorizes the Council to designate an area

as an AINR if "[t]he designation . . . is consistent with smart growth planning

principles adopted pursuant to law or regulation." N.J.S.A. 40A:12A-5(h). The

report does not explain how designation of the Property as an AINR is consistent

with smart growth principles, which it identifies as "concentrate[d] growth in

compact walkable urban centers to avoid sprawl."

Finally, the report states the Property qualifies as an AINR under N.J.S.A.

40A:12A-3. That statute provides an ANIR "may include lands, buildings, or

improvements which of themselves are not detrimental to the public health,

safety or welfare, but the inclusion of which is found necessary, with or without

change in their condition, for the effective redevelopment of the area of which

they are a part." N.J.S.A. 40A:12A-3. The report does not explain why

inclusion of the Property in the AINR is necessary to redevelop other parcels in

the Non-Condemnation Study Area or the Sixth Street Embankment Study Area.

A-1246-22 5 Conrail submitted written objections to the Board contesting inclusion of

the Property in an AINR. Conrail argued: (1) the Interstate Commerce

Commission Termination Act (ICCTA), 49 U.S.C.A. §§ 701 to 727 and §§

10101 to 16106, preempts local zoning and land-use regulation of the Property,

including designation as an AINR, because the Property is the site of an active

rail line; (2) the Property does not meet the statutory criteria for designation as

an AINR; and (3) declaring the Property in need of redevelopment would be a

waste of time and money because Conrail has no desire to use the Property for

any purpose other than railroad use.

At the Board's July 6, 2021 meeting, Krehel testified that getting to the

Property is a "challenge" but admitted "[t]here are access points." In addition,

he acknowledged Conrail presumably uses the lots without active rail operations

to access the lots with active rail operations. Krehel did not explain why the

Property was unlikely to be developed through private capital in the event its

railroad use was abandoned or why Conrail would permit the Property to be

developed for any use other than railroad use.

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