Background
Landowners along approximately 175 miles of a former railroad corridor in Mendocino, Trinity, and Humboldt Counties, California, brought Fifth Amendment takings claims after the Surface Transportation Board issued a Notice of Interim Trail Use or Abandonment for the planned Great Redwood Trail. They alleged that they owned fee interests beneath the railroad right-of-way and that federal railbanking prevented those interests from reverting to their full use.
In this second summary-judgment ruling, the court considered competing motions concerning 16 parcels owned by eight representative plaintiffs. The landowners sought to establish ownership through California’s centerline presumption or through historical chains of title. The government argued that the deeds’ metes-and-bounds descriptions rebutted the presumption, that certain deeds expressly excluded corridor land, and that the title records did not establish ownership.
The Court’s Holding
The court held that the deeds in Groups E, F, and G described the parcels in a manner that rebutted California’s centerline presumption. It also held that the Group H deeds excluded fee interests in the railroad right-of-way rather than merely notifying the grantees that the conveyed land was subject to a railroad easement. The affected plaintiffs therefore had to prove ownership through their chains of title.
For the parcels requiring chain-of-title proof, the court held that plaintiffs failed to establish a fee interest in nine parcels, established such an interest in one parcel owned by Steven Danielson, and raised genuine disputes of material fact concerning four parcels owned by the Nyberg Revocable Trust. Danielson’s victory addressed fee ownership only, not government liability or damages. The court granted and denied each side’s motions in part; it also denied the cross-motions as moot for two parcels whose claims had already been resolved for the government because the railroad held the right-of-way in fee.
Key Takeaways
- Under California law, a sufficiently specific metes-and-bounds description ending at a railroad right-of-way’s sideline can rebut the centerline presumption.
- A plaintiff whose deed does not carry the centerline presumption must present evidence showing that a predecessor owned the corridor fee and passed it through the chain of title.
- Uncertainty about who else owns corridor land does not defeat summary judgment when the plaintiff bears the burden of proving a cognizable property interest.
Why It Matters
The ruling illustrates that adjacency to a rail corridor alone does not establish the property interest required for a rails-to-trails taking. Deed language and historical conveyances can determine whether a claimant reaches the later questions of taking, liability, and compensation.
It also shows that gaps in historical records are not automatically fatal, but plaintiffs still must produce affirmative evidence of their own ownership. Where competing evidence or ambiguous parcel descriptions require factfinding, summary judgment is inappropriate.