Caquelin v. United States
121 Fed. Cl. 658
Fed. Cl.2015Background
- This is a rails-to-trails takings case in the United States Court of Federal Claims seeking compensation for a NITU-driven conversion of a 10.46-mile Iowa rail corridor into a public trail.
- Plaintiffs Caquelin own adjacent parcels; the rail corridor rights were acquired by North Central Railway through an 1870 deed and a 1870 condemnation, creating easements for railroad purposes.
- Plaintiffs allege they hold fee simple title up to the centerline, while the railroad held only easements restricted to railroad purposes.
- The STB issued a NITU on July 3, 2013, delaying abandonment and initiating negotiations for railbanking and interim trail use, with a 180-day negotiation window.
- No trail-use agreement was reached; the NITU expired December 30, 2013, and the railroad fully abandoned the line in March 2014.
- Plaintiffs filed suit January 16, 2014, alleging a taking by the government for blocking reversion of their state-law interests and delaying compensation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether North Central held only easements or fee simple estates. | Caquelin asserts fee simple ownership in the parcels and the centerline. | United States treats the railroad as owning an easement for railroad purposes only. | Plaintiffs owned fee simple; railroad held easement only; analysis proceeds to scope and termination. |
| Whether the NITU exceeded the easement’s scope by contemplating trail use. | Caquelin argues NITU blocked reversion and expanded use beyond railroad purposes. | United States contends NITU’s limited duration and no interim use render the issue irrelevant. | NITU exceeded the easement scope, triggering a taking. |
| When did the taking accrue for purposes of liability. | Caquelin argues accrual aligns with the triggering of the NITU, per Preseault line of authority. | United States relies on Caldwell/Barclay distinctions about accrual timing. | Accrual occurred on July 3, 2013, the date of the NITU issuance. |
Key Cases Cited
- Ladd v. United States, 630 F.3d 1015 (Fed. Cir. 2010) (accrual occurs at NITU issuance; taking may be temporary but liability attaches then)
- Caldwell v. United States, 391 F.3d 1226 (Fed. Cir. 2004) (NITU as trigger for potential taking; timing of accrual discussed)
- Barclay v. United States, 443 F.3d 1368 (Fed. Cir. 2006) (accrual on the date of NITU issuance; temp vs permanent taking considerations)
- Preseault v. United States, 100 F.3d 1525 (Fed. Cir. 1996) (establishes three-part Preseault II framework for rails-to-trails takings)