Kent v. United States

CourtUnited States Court of Federal Claims
DecidedJanuary 17, 2025
Docket15-365
StatusPublished

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

Opinion

In the United States Court of Federal Claims Nos. 15-365 L; 18-1591 L Filed: January 17, 2025 ________________________________________ ) KENT, et al., ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ) ________________________________________ )

Altom M. Maglio, mctlaw, Sarasota, Florida, with whom was Jeffrey Charles Nelson, Maglio Christopher & Toale, P.A., Washington, D.C., of counsel, and Laura Gaskill, Gaskill Law Firm, P.A., Sarasota, Florida, for Plaintiffs.

Sean Christian Duffy, Natural Resources Section, Environment and Natural Resources Division, United States Department of Justice, Washington, D.C., Todd Kim, Assistant Attorney General, Environment and Natural Resources Division, United States Department of Justice, and Jean E. Williams, Deputy Assistant Attorney General, Environment and Natural Resources Division, United States Department of Justice for Defendant.

OPINION AND ORDER

MEYERS, Judge.

I. Background

The conveyances at issue in this rails-to-trails case date to the late 1800s. ECF No. 97-1 at 231. 1 CSX Transportation Inc. eventually became the railroad 2 line operator. Id. at 115–16. In 2013, the railroad filed a notice of exemption with the Surface Transportation Board (“STB”)

1 Because ECF No. 97-1 contains several documents and is not consecutively paginated, the court cites to the pagination in the ECF Header. 2 Because the specific railroad that received the property at issue 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 that obtained the property at issue. to abandon a rail line 3 in Alachua County, Florida. Id. at 11. The STB later issued a Notice of Interim Trail Use (“NITU”) concerning the line, invoking the Trails Act, 16 U.S.C. § 1247(d). Id. at 6–8.

Fourteen plaintiffs initially sued, alleging a taking of their reversionary interests in the land underlying the rail line. Three remain: Loncala, Inc. (“Loncala”), Robert Michael Shea, and Glenda Green. ECF No. 97 at 8–9. These three plaintiffs have predecessors-in-interest who conveyed an interest in the land underlying the rail line to the railroad. Those interests stem from six deeds and bonds. Id. The Plaintiffs contend that each created only an easement to operate a railroad across the property:

• Plaintiff Loncala’s claim rests on the High Springs Phosphate Deed. Id. • Plaintiff Green’s claim rests on the Imperial Phosphate Deed, the Pyles Bond, and the Wright Deed. Id. • Plaintiff Shea’s claim rests on the Price Florida Deed and the Price Savannah Deed. Id.

The Government has conceded that the High Springs Phosphate Deed created an easement. ECF No. 101 at 18. Plaintiff Green has abandoned her argument regarding the Pyles “deed” because it is a “bond that did not . . . convey an easement.” ECF No. 97 at 9; ECF No. 135 at 5 n.1. The Parties dispute whether the interests conveyed by the remaining deeds transferred an easement to the railroad—in which case the Plaintiffs allege they are entitled to compensation for a taking of their property—or fee simple title to the railroad—in which case the Plaintiffs have suffered no taking. ECF No. 97 at 9; ECF No. 101 at 1.

Both parties move for summary judgment regarding the interpretation of the conveyances.

II. Standard of Review

Under Rule 56, “[t]he court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Rules of the Court of Federal Claims (“RCFC”) 56(a). The movant has the initial burden to show that there is no genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). A “genuine” dispute of material fact exists where a reasonable jury “could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). And a “material” fact is one “that might affect the outcome of the suit under governing law,” as opposed to “disputes that are irrelevant or unnecessary.” Id.

If the movant meets its initial burden, the burden shifts to the nonmovant to show a genuine dispute of material fact. Id. at 256–57. The nonmovant can do this by “citing to particular parts of materials in the record” or by “showing that the materials cited do not

3 The line is located on “CSXT’s Southern Region, Jacksonville Division, West Coast Subdivision, between milepost AR 716.88, at High Springs and milepost AR 726.69, at Newberry, and milepost ARB 717.11, at High Springs and milepost ARB 718.92, at High Springs in Alachua County, FL.” ECF No. 97 at 5. 2 establish the absence . . . of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact.” RCFC 56(c)(1). “By its very terms, this standard provides that the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.” Anderson, 477 U.S. at 247–48 (emphasis in original). And while the “evidence of the nonmovant is to be believed, and all justifiable inferences are to be drawn in his favor[,]” id. at 255, the nonmovant’s evidence must be “significantly probative” and more than “merely colorable” to defeat summary judgment, id. at 249–50.

III. Discussion

A. Rails-to-Trails Takings Actions

Congress created the Trails Act “to preserve shrinking rail trackage by converting unused rights-of-way to recreational trails.” Rogers v. United States (Rogers I), 90 Fed. Cl. 418, 427 (2009) (citing Preseault v. Interstate Com. Comm’n (Preseault I), 494 U.S. 1, 5 (1990)); see also 16 U.S.C. § 1241 et seq. To convert the right-of-way into a recreational trail, “the railroad must either (1) file a standard abandonment application with the STB or (2) seek an exemption from filing the application.” Mills v. United States, 147 Fed. Cl. 339, 344 (2020) (citing Caldwell v. United States, 391 F.3d 1226, 1228 (Fed. Cir. 2004)). If the standard abandonment application is approved or the exemption is granted, “the railroad ceases operation, the STB relinquishes jurisdiction over the abandoned railroad right-of-way and state law reversionary property interests, if any, take effect.” Id. (citing Caldwell, 391 F.3d at 1228–29). But if an entity expresses its willingness to take on the rail corridor as a recreational trail before final abandonment, the STB issues a Notice of Interim Trail Use, or NITU. Caldwell v. United States, 391 F.3d at 1229 (Fed. Cir. 2004). A NITU allows the railroad and trail sponsor to negotiate a transfer to the trail sponsor to use the rail corridor as a recreational trail. If they reach an agreement, the railroad transfers the rail corridor to the trail sponsor to operate and the underlying landowner does not get the unencumbered use of their property back. Id.

Of course, when “private property interests are taken by the Government pursuant to the Trails Act, the property owners are entitled to just compensation.” Rogers I, 90 Fed. Cl. at 427 (citing Preseault I, 494 U.S. at 13); U.S. Const. amend. V.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Preseault v. Interstate Commerce Commission
494 U.S. 1 (Supreme Court, 1990)
Caldwell, Iii v. United States
391 F.3d 1226 (Federal Circuit, 2004)
Thrasher v. Arida
858 So. 2d 1173 (District Court of Appeal of Florida, 2003)
Venice East, Inc. v. Manno
186 So. 2d 71 (District Court of Appeal of Florida, 1966)
Trailer Ranch, Inc. v. City of Pompano Beach
500 So. 2d 503 (Supreme Court of Florida, 1986)
Saltzman v. Ahern
306 So. 2d 537 (District Court of Appeal of Florida, 1975)
Financial Healthcare Associates, Inc. v. Public Health Trust
488 F. Supp. 2d 1231 (S.D. Florida, 2007)
Stephen J. Rogers v. United States
184 So. 3d 1087 (Supreme Court of Florida, 2015)
Rogers v. United States
814 F.3d 1299 (Federal Circuit, 2015)
Seaboard Air Line Railway Co. v. Dorsey
149 So. 759 (Supreme Court of Florida, 1932)
Atlantic Coast Line Railroad Co. v. Duval Cty.
154 So. 331 (Supreme Court of Florida, 1934)
Reid v. Barry
112 So. 846 (Supreme Court of Florida, 1927)
Robb v. Atlantic Coast Line Railroad
117 So. 2d 534 (District Court of Appeal of Florida, 1960)
Campbell v. Abraham
152 So. 2d 309 (Louisiana Court of Appeal, 1963)
Rogers v. United States
90 Fed. Cl. 418 (Federal Claims, 2009)
Rogers v. United States
93 Fed. Cl. 607 (Federal Claims, 2010)
Whispell Foreign Cars, Inc. v. United States
97 Fed. Cl. 324 (Federal Claims, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Kent v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kent-v-united-states-uscfc-2025.