HYATT v. United States

CourtUnited States Court of Federal Claims
DecidedJanuary 14, 2025
Docket23-499
StatusPublished

This text of HYATT v. United States (HYATT 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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HYATT v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 23-499 Filed: January 14, 2025

RICKEY A. HYATT and BARBARA HYATT,

Plaintiffs,

v.

THE UNITED STATES,

Defendant.

Lindsay S.C. Brinton, Meghan S. Largent, and Michael Armstrong, Lewis Rice LLC, St. Louis, Missouri, with J. Nathan Duggins, III, Michael S. Fox, and Jason B. Sparrow, Tuggle Duggins, P.A., Greensboro, North Carolina, for Plaintiffs.

Peter W. Brocker, Natural Resources Section, with Todd Kim, Assistant Attorney General, Environment & Natural Resources Division, U.S. Department of Justice, Washington, D.C., for Defendant.

MEMORANDUM OPINION AND ORDER

TAPP, Judge.

The Court has already described this litigation as “a typical rails-to-trails action where the United States infringed Plaintiffs’ property rights for a public improvement project.” Hyatt v. United States, 170 Fed. Cl. 417, 429 (2024); Nicholson v. United States, 170 Fed. Cl. 399, 411 (2024). 1 In cases like this, the Uniform Relocation Assistance and Real Property Acquisition Policies Act (“URA”) provides a vehicle to reimburse reasonable fees and incurred expenses. This mechanism is crucial in ensuring access to justice for property owners whose rights are implicated in eminent domain proceedings. Having successfully defended their rights, Plaintiffs move for an award of reasonable attorneys’ fees and costs. Plaintiffs’ request is supported by

1 The Court manages two related cases on this rail corridor, Rickey A. Hyatt and Barbara Hyatt v. United States, Case No. 23-499, and Daniel Nicholson and Patricia Midgett v. United States, Case No. 23-843. The parties filed joint briefing during summary judgment and similar briefing on this matter. This Opinion addresses both cases and will be filed on both dockets, the only difference will be the captions. To the extent the Court refers to a specific filing, it will denote that filing with the label Hyatt or Nicholson. This follows the Court’s method in its Summary Judgment Opinions. (See Hyatt ECF No. 30; Nicholson ECF No. 25). reliable evidence and applicable law, demonstrating that a fee award is warranted for the significant costs incurred in guarding their constitutional rights.

I. Background 2

Plaintiffs are North Carolinian property owners subject to a rail easement owned by Norfolk Southern Railway Company (“Norfolk Southern”). Hyatt, 170 Fed. Cl. at 424–45; Nicholson, 170 Fed. Cl. at 405–406. To expand a vast inner-city trail network, Norfolk Southern sold its interest in a 3.1-mile rail corridor to the City of Greensboro, North Carolina. 170 Fed. Cl. at 422. The sale was contingent upon successfully railbanking the corridor via The National Trails System Act, 16 U.S.C. §§ 1241–51 (“The Trails Act”). Id. Based on the easement conversions on their respective properties, Plaintiffs initiated litigation in the spring of 2023. Id. (see also Hyatt Compl., ECF No. 1 (filed April 12, 2023); Nicholson Compl., ECF No. 1 (filed June 7, 2023)).

The following fifteen months of litigation were relatively nondescript. In short, the Court decided liability for Plaintiffs, resulting in a settlement agreement of $100,892, collectively. 170 Fed. Cl. 417; 170 Fed. Cl. 399; (see Hyatt Def.’s Resp. at 1, ECF No. 39; Nicholson Def.’s Resp. at 1, ECF No. 32 (collectively referred to as “Def.’s Resp.”); Hyatt Pls.’ Reply at 1, ECF No. 40; Nicholson Pls.’ Reply at 1, ECF No. 33 (collectively referred to as “Pls.’ Reply”)). 3 However, the journey to settlement was not direct. Based on the nature of Plaintiffs’ Motions, the Court reviews the timeline broadly.

After the United States responded to the Complaints, it moved to consolidate Hyatt and Nicholson. (Hyatt Mot. to Consol., ECF No. 6). Plaintiffs objected for their own case management purposes. (Hyatt Resp. to Mot. to Consol., ECF No. 7). The Joint Preliminary Status Report highlighted the possibility that discovery in other, tangentially related cases, where

2 The Court issued a substantive Summary Judgment ruling on March 13, 2024. Hyatt v. United States, 170 Fed. Cl. 417 (2024); Nicholson v. United States, 170 Fed. Cl. 399 (2024). Insomuch as they are relevant here, the Court reiterates those findings. This section provides context for the following analysis by briefly reviewing the background and summarizing the key litigation events. 3 Plaintiffs filed separate “Motions for Attorney Fees and Litigation Expenses Under the URA” in both Hyatt and Nicholson, including different figures but similar arguments. (Hyatt Pls.’ Mot., ECF No. 38; Nicholson Pls.’ Mot., ECF No. 31). Thus, the Court refers to those motions separately. Defendant’s Response in opposition to the requested fees, (Hyatt Def.’s Resp., ECF No. 39; Nicholson Def.’s Resp., ECF No. 32), and Plaintiffs’ Reply, (Hyatt Pls.’ Reply, ECF No. 40; Nicholson Pls.’ Reply, ECF No. 33), contain captions for both cases. The Court refers to those briefs collectively as “Def.’s Resp.” and “Pls.’ Reply.”

2 discovery had already been conducted, may influence the discovery process in this matter. 4 (Joint Preliminary Status Report (“JPSR”) at 2, ECF No. 10). This caused the parties some disagreement as to how to best proceed with discovery. (Id. at 4–6).

Plaintiffs proposed bifurcation into: (1) a title-determination and liability phase; and (2) a just compensation phase assuming Plaintiffs were successful during the initial phase. (JPSR at 2). At that point, Plaintiffs had already exchanged their RCFC 26 disclosures. (Id. at 3). The United States opposed bifurcation and proposed that the case proceed on an expedited schedule. (Id. at 5). Its justification was that Plaintiffs’ counsel and the “United States ha[d] already been through discovery in the earlier filed cases at least three times (indeed, [P]laintiffs’ counsel . . . conducted two trials in those earlier cases on the basis of that discovery), [thus] the parties need not engage in duplicative discovery efforts again in these matters.” (Id. (emphasis in original)). Even so, the United States also averred its belief that “further exploration of the facts is necessary before they can determine the likelihood of settlement.” (Id. at 9). In that report, the parties’ proposed schedules varied based on their divergence of opinion on moving the case forward. (Id. at 11–12).

The Court scheduled an in-person hearing to address the parties’ differing stances on the Motion to Consolidate, the issue of bifurcating trial, the potential for combined fact and expert discovery, the parties’ proposed litigation timelines, and the litigation history of related cases. (Hyatt ECF No. 12; see also Sept. 5, 2023 Tr. 4:6–8 (Court establishing that this proceeding was to facilitate “discussion about where we’re going to go in this case and how we’re going to get there.”), Hyatt ECF No. 15). That conference highlighted the parties’ conflicting positions. Plaintiffs began by reiterating their objections to any form of consolidation. (Sept. 5, 2023 Tr. 12:14–25 (Pls.’ Counsel: “The case of Hyatt and the case of Nicholson are not directly related cases. They’re indirectly related cases, just as are all of these Greensboro litigation.” “[The cases] involve separate Plaintiffs, separate properties, separate appraisal issues[,] [a]nd . . . consolidation is not efficient, and it actually wreaks many problems at the end of the case when you try and resolve singular cases, when you have multiple cases altogether.”)).

During the conference, Plaintiffs went on to detail their progress toward discovery, including their Claims Book submission in July, but they indicated that the United States had not responded. (Id. at 4:14–18).

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