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Santa Fe Pac. R.R. Co. v. United States

Citation: 32 ELR 20766
No. No. 01-5063, 294 F.3d 1336/(Fed. Cir., 06/17/2002)

The court affirms the U.S. Court of Federal Claims' holding that the passage of the Resolution of Western Lands Dispute Act did not effect a taking of a railroad's land. When the railroad was incorporated in 1866, it was granted large areas of public land by the U.S. government. In exchange for the land, the railroad was required to carry government freight and personnel at reduced rates. In 1897, the government enacted a statute that offered to owners of land within the boundaries of a designated forest reserve the right to exchange their land for an equal area of available federal land outside the forest reserve, and in 1902, the railroad exchanged 882,358 acres of land located in forest reserves. In 1940, the railroad acted on a statute passed by the U.S. government relieving the railroads of their obligation to carry government personnel and freight at reduced rates in exchange for the release of any claims against the government to interests in, compensation, or reimbursement for lands. The Resolution of Western Lands Dispute Act, passed in 1993, directed the U.S. Department of the Interior (DOI) and the U.S. Department of Agriculture to identify all of the parcels of land that the railroads had relinquished to the United States but for which selection or other rights had not been exercised and to quitclaim the original lands back to the railroads, unless they were identified as nationally significant lands. The lands at issue here were identified as nationally significant lands.

The court first holds that the Federal Claims Court correctly held that no taking occurred. The release executed by the railroad in accordance with the 1940 act was a broad release of all claims on account of the railroad land grants. Additionally, the railroad did not suffer a taking based on equitable interests retained in its base lands that were conditionally relinquished in the 1902 agreements. The nature of any equitable or conditional interest in the transferred lands before the 1940 release is no longer relevant because any such rights arising from the 1902 contracts were released upon the DOI's acceptance of the railroad's 1940 release.

The full text of this decision is available from ELR (16 pp., ELR Order No. L-539).

Counsel for Plaintiff
Jerome C. Muys
Muys & Associates
1575 I St. NW, Washington DC 20005
(202) 737-5205

Counsel for Defendant
Kristine S. Tardiff
Environment and Natural Resources Division
U.S. Department of Justice, Washington DC 20530
(202) 514-2000