NOLAN v. United States

CourtUnited States Court of Federal Claims
DecidedOctober 28, 2024
Docket21-122
StatusPublished

This text of NOLAN v. United States (NOLAN 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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NOLAN v. United States, (uscfc 2024).

Opinion

In the United States Court of Federal Claims FOR PUBLICATION

No. 21-122L (Filed: October 28, 2024)

) RICHARD J. NOLAN, et al., ) ) Plaintiffs, ) v. ) ) UNITED STATES, ) ) Defendant. )

Nicolas J. Rotsko, Fluet, Tysons, VA, for plaintiffs.

Mark A. Pacella, Trial Attorney, Natural Resources Section, Environmental and Natural Resources Division, U.S. Department of Justice, Washington, DC, for defendant. With him on the briefs was Todd Kim, Assistant Attorney General, and Tara M. Lewis, Ashley M. Carter, and Sarah Ruckriegle, Trial Attorneys, Natural Resources Section, Environmental and Natural Resources Division, U.S. Department of Justice, Washington, DC.

OPINION AND ORDER1

BONILLA, Judge.

Landowners in Pottawattamie County, Iowa, located within the Missouri River Basin, allege the U.S. Army Corps of Engineers (Corps) intentionally and repeatedly flooded their properties between 2007 and 2019. They attribute the flooding to actions taken by the Corps in response to a 2004 shift in government priorities from promoting regional investment and property development through flood control to environmental and wildlife protection by restoring the river’s natural flow. The

1 This case was transferred to the undersigned for adjudication on October 3, 2022, pursuant to

Rule 40.1(b) of the Rules of the United States Court of Federal Claims (RCFC). At that time, and continuing through January 5, 2024, the matter was stayed pending final resolution of an appeal to the United States Court of Appeals for the Federal Circuit in a related case, Ideker Farms, Inc. v. United States, 71 F.4th 964 (Fed. Cir. 2023), reh’g en banc denied (Nov. 29, 2023) (per curiam). landowners seek just compensation under the Fifth Amendment to the United States Constitution for the per se taking of their land and related personal property damage caused by the now-permanent (recurring) flowage easement.

Pending before the Court is defendant’s motion to dismiss plaintiffs’ amended complaint for lack of subject matter jurisdiction or, in the alternative, for failure to state a claim upon which relief can be granted pursuant to RCFC 12(b)(1) and 12(b)(6). Specifically, defendant asserts plaintiffs waited too long to file this action and, further, that plaintiffs fail to allege cognizable property interests or plead their claims with the requisite specificity. The Court finds plaintiffs failed bring this action within six years of the applicable accrual date, rendering their claims time-barred. Accordingly, defendant’s motion to dismiss under RCFC 12(b)(1) is GRANTED.2

BACKGROUND3

Until the early twentieth century, the Missouri River was free flowing, flooding adjacent and nearby lands and rendering the surrounding area economically undevelopable.4 Beginning in the late 1920s, Congress authorized the construction of dams, dikes, and levees to contain and regulate river flow, culminating in the enactment of the Flood Control Act of 1944, 33 U.S.C. § 701 et seq., and the establishment of the Pick-Sloan Missouri Basin Program (f/k/a Missouri River Basin Program). These flood control measures, implemented by the Corps, were designed to spur economic development and agricultural investment in the region by creating large swathes of arable land from the former floodplain. The legislation and program also improved river navigation and provided a consistent supply of water for irrigation and municipalities. The U.S. Department of Agriculture instituted complementary programs easing land management regulations and facilitating financing.5 Relevant here, fish and wildlife preservation took a backseat to these initiatives. The development of the Missouri River Basin led to an expansion of over 300,000 acres of farmland and a population growth of roughly twelve million new residents.

2 In dismissing this action for lack of subject matter jurisdiction, the Court does not reach defendant’s

alternative dispositive motion under RCFC 12(b)(6). 3 The facts are drawn from plaintiffs’ amended complaint and publicly available information. See Bitscopic, Inc. v. United States, 166 Fed. Cl. 677, 696 (2023) (“The court is not limited to the pleadings to assure itself of its jurisdiction; it may ‘inquire into jurisdictional facts’ to confirm jurisdiction.”) (quoting Rocovich v. United States, 933 F.2d 991, 993 (Fed. Cir. 1991)). 4 The history of the Missouri River and the government’s initial flood control efforts followed by the

reversion to a more natural state to benefit wildlife preservation are detailed in Ideker Farms, Inc. v. United States, 136 Fed. Cl. 654, 660–72 (2018). A high-level summary of the critical facts is included herein for context. 5 See, e.g., Memorandum Prepared for the Missouri Basin Inter-Agency Committee, The Department

of Agriculture and the Missouri River Basin (Apr. 1946), available at https://perma.cc/BG2N-TDKW (last visited Oct. 24, 2024).

2 Toward the end of the century, in the face of increased pressure from environmental and wildlife conservation organizations, the pendulum began swinging back towards allowing the river to flow naturally. As reflected in a January 1992 Report to Congress by the General Accounting Office (n/k/a Government Accountability Office):

After the enactment of the Endangered Species Act of 1973, [16 U.S.C. §§ 1531–1544,] the Corps gave priority to fish and wildlife protection for threatened and endangered species over all authorized purposes except flood control. According to the Corps, other [municipal and industrial] water supply, and private irrigation uses of water within the reservoir system are authorized only if surplus reservoir water is available.

See https://perma.cc/9CA7-BA8F at 13 (last visited Oct. 28, 2024). The subsequent passage of the Water Resources Development Act of 1986, 33 U.S.C. § 2201 et seq., as amended, and the resulting Missouri River Fish and Wildlife Mitigation Project, prioritized restoring the habitats and ecosystems of threatened and endangered fish and wildlife over flood-control efforts. Biological opinions issued by the U.S. Fish and Wildlife Services in 2000 and 2003 further hastened the Corps’ shift in priorities. See, e.g., In re Operation of the Mo. River Sys. Litig., 305 F. Supp. 2d 1096, 1099 (D. Minn. 2004).

Following judicial intervention through multi-district litigation, the Corps revised its 1979 Missouri River Master Water Control Manual (Master Manual) in March 2004 and launched the Missouri River Recovery Program. See id. As succinctly explained by the Federal Circuit: “Unlike the 1979 Master Manual that prioritized flood control over wildlife, the 2004 Master Manual eliminated prioritization.” Ideker Farms, 71 F.4th at 973. The Missouri River has since been restored to a more natural state, resulting in increased and recurring regional flooding since 2007.

On March 5, 2014, more than one hundred landowners and farmers neighboring the Missouri River filed suit in this Court alleging that the Corps’ implementation of the 2004 changes to the Master Manual “caused frequent and severe flooding on [their] farms between 2007 and 2014 that amounted to permanent, physical takings under the Fifth Amendment.” Id. In an amended complaint filed seven months later, the number of plaintiffs grew to nearly four hundred across six states, including Iowa.

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