Union Pacific Railroad Company v. Illinois Mine Subsidence Insurance Fund

CourtDistrict Court, C.D. Illinois
DecidedDecember 22, 2025
Docket3:20-cv-03281
StatusUnknown

This text of Union Pacific Railroad Company v. Illinois Mine Subsidence Insurance Fund (Union Pacific Railroad Company v. Illinois Mine Subsidence Insurance Fund) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Union Pacific Railroad Company v. Illinois Mine Subsidence Insurance Fund, (C.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

UNION PACIFIC RAILROAD ) COMPANY, ) ) Plaintiff, ) ) v. ) Case No. 20-cv-3281 ) ILLINOIS MINE SUBSIDENCE ) INSURANCE FUND, ) ) Defendant. )

OPINION AND ORDER

SUE E. MYERSCOUGH, U.S. District Judge: Now before the Court is Plaintiff Union Pacific Railroad Company’s (“Union Pacific”) Motion for Summary Judgment (d/e 65) and Defendant Illinois Mine Subsidence Insurance Fund’s (“the Fund”) Motion for Summary Judgment (d/e 75). For the reasons set forth, Union Pacific’s Motion for Summary Judgment (d/e 65) is GRANTED in PART and DENIED in PART and the Fund’s Motion for Summary Judgment (d/e 75) is GRANTED in PART and DENIED in PART. I. INTRODUCTION On October 20, 2020, Union Pacific filed its original Complaint

for declaratory and injunctive relief in this Court (d/e 1). On August 25, 2022, Union Pacific filed its Second Amended Complaint containing three counts (d/e 42). Only Count I and the

corresponding part of Count III of the Second Amended Complaint remain at issue before this Court. See d/e 47. In Count I, Union Pacific seeks several declarations. See d/e

42, ¶¶ 30, 31, 33. Union Pacific first requests a declaration, “consistent with” this Court’s March 31, 2022 Order, stating that issue preclusion bars the Fund’s claims acquired before the entry of

judgment in a 2015 case and a 2017 case against Union Pacific. Id. at ¶ 30. Union Pacific also requests a declaration defining when a claim is “acquired,” and a declaration stating that the Fund “is the

real party in interest” and “in privity” once reimbursements are made. Id. at ¶¶ 31, 33. Union Pacific then alleges in Count I that claim preclusion bars the Fund “and its privies…from relitigating any theory it raised

or could have raised in the 2017 Case.” Id. at ¶ 36. Union Pacific alleges that “[t]here is an identity of parties and a final judgment on the merits,” and that “the facts out of which any liability could arise

are necessarily the facts” underlying the 2017 case, such that the Fund “could have asserted all claims it had acquired without changing what was litigated and decided” when litigating the 2017

Case. Id. at ¶¶ 36-37. In Count III, Union Pacific requests an injunction in support of any declarations made in Count I, as well as the injunction that the

Court in its March 31, 2022 Order held that Union Pacific may be entitled to seek in the 2017 Case. Id. at ¶¶ 50–54; see also d/e 38, p. 21.

On March 26, 2024, this Court dismissed Count II and the corresponding part of Count III of the Second Amended Complaint. See d/e 47. Union Pacific filed an interlocutory appeal of this

Court’s dismissal of Count II and the corresponding part of Count III, which the Seventh Circuit Court of Appeals dismissed on June 6, 2025 for lack of appellate jurisdiction. See d/e 52, d/e 73. On November 4, 2024, Union Pacific filed a Motion for

Summary Judgment (d/e 65) and Memorandum in Support (d/e 66). On November 25, 2024, the Fund filed a Memorandum in Opposition (d/e 68), to which Union Pacific filed a Reply on

December 9, 2024 (d/e 69). On July 14, 2025, the Fund filed a Motion for Summary Judgment and Memorandum in Support (d/e 75). On August 4,

2025, Union Pacific filed a Memorandum in Opposition (d/e 76), to which the Fund filed a Reply on August 28, 2025 (d/e 77). II. LEGAL STANDARD

Summary judgment is proper if the movant shows that no genuine dispute exists as to any material fact and that the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). A

genuine dispute of material fact exists if a reasonable trier of fact could find in favor of the non-moving party. Carroll v. Lynch, 698 F.3d 561, 564 (7th Cir. 2012).

When ruling on a motion for summary judgment, the Court must construe facts in the light most favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s favor. Woodruff v. Mason, 542 F.3d 545, 550 (7th Cir. 2008). “At

summary judgment, ‘a court may not make credibility determinations, weigh the evidence, or decide which inferences to draw from the facts; these are jobs for a factfinder.’” Paz v.

Wauconda Healthcare & Rehab. Ctr., LLC, 464 F.3d 659, 664 (7th Cir. 2006). The movant bears the initial responsibility of informing the

Court of the basis for the motion and identifying the evidence the movant believes demonstrates the absence of any genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986);

Modrowski v. Pigatto, 712 F.3d 1166, 1168 (7th Cir. 2013) (explaining that Rule 56 “imposes an initial burden of production on the party moving for summary judgment to inform the district court

why a trial is not necessary” (internal citation omitted)). After the moving party does so, the non-moving party must then go beyond the pleadings and “set forth specific facts showing that there is a

genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986) (quotation and footnotes omitted). III. FACTS The Court draws the following facts from the parties’

statements of undisputed material facts. The Court discusses any material factual disputes in its analysis. Immaterial facts or factual disputes are omitted. Any fact submitted by any party that was not

supported by a citation to evidence will not be considered by the Court. See Local Rule 7.1(D)(2)(b)(2). In addition, if any response failed to support each allegedly disputed fact with evidentiary

documentation, that fact is deemed admitted. Id. The Illinois Legislature created the Fund to provide insurance companies reinsurance for certain mine subsidence damage claims.

See d/e 66, ¶ 1; d/e 68, p. 10; d/e 75, ¶ 1; d/e 76, p. 8; see also Illinois Mine Subsidence Act (“the Act”), 215 ILCS 5/803.1 et seq. The Act requires Illinois property insurers to provide mine

subsidence coverage and the Fund to fully reinsure the coverage subject to a statutory coverage cap and other conditions specified in the Act. See d/e 66, ¶ 2; d/e 68, p. 10; d/e 75, ¶ 2; d/e 76, p. 8;

see also 215 ILCS 5/805.1, 5/810.1. The Fund sets and receives the premiums less a ceding premium to the property insurer, which must secure subrogation rights so the Fund can assert them. See d/e 66, ¶ 3; d/e 68, p. 8; d/e 75, ¶ 3; d/e 76, p. 8; see also 215

ILCS 5/811.1, 5/815.1. From 1904 to 1953, the Superior Coal Company (“Superior”) operated four coal mines in Macoupin County, Illinois. See d/e 66,

¶ 4; d/e 68, pp. 8; d/e 75, ¶ 4; d/e 76, p. 8. In 1957, Superior was dissolved, and pursuant to the relevant governing statute at the time, actions could be brought against Superior for only two years

after its dissolution. See d/e 66, ¶¶ 4-6; d/e 68, p. 8; d/e 75, ¶ 4; d/e 76, p. 8. In 1995, Superior’s parent company, the Chicago and North

Western Railway Company, merged into Union Pacific. See d/e 75, ¶ 4; d/e 76, p. 8.

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Union Pacific Railroad Company v. Illinois Mine Subsidence Insurance Fund, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-pacific-railroad-company-v-illinois-mine-subsidence-insurance-fund-ilcd-2025.