Haggart v. United States, 131 Fed. Cl. 628

Background

This is a rails-to-trails takings class action (Haggart) involving ~25.45 miles of former railroad right-of-way in King County, WA; plaintiffs allege Trails Act conversion constituted a Fifth Amendment taking.
The court earlier certified a class, divided it into six subclasses, and granted partial summary judgment for plaintiffs as to liability for certain members of Subclasses Two and Four (reserving some ownership issues for trial).
Parties mediated and executed a comprehensive settlement agreement (June 18, 2014) for a specified total payment ($110M principal + interest; specific per-plaintiff allocations in an attachment), which the Court of Federal Claims approved; some class members objected, seeking more documentary disclosure of valuation methodology.
On appeal the Federal Circuit reversed the settlement approval and attorneys’ fees award, holding that documentary disclosure of the valuation methodology for non‑appraised properties was required to permit objectors to verify their awards, and remanded for further proceedings.
On remand the court ordered disclosure; parties could not reallocate the fixed settlement fund. The government then sought to relitigate liability issues (invoking a related district‑court decision in Kaseburg), while plaintiffs moved to enforce the settlement as a binding contract.
The court held the settlement remains enforceable, denied the government’s motions to reconsider or for summary judgment, and ordered the parties to attempt renewed mediation or, if necessary, further proceedings limited to allocation of the agreed fund among settling plaintiffs.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prior liability rulings (Subclass Two & Four) are binding on remand under the mandate rule / law of the case	Haggart: prior liability determinations were part of the final judgment and remain binding	United States: earlier liability rulings were interlocutory and may be revisited after remand	Court: liability rulings were embedded in the 2014 final judgment and are subject to the mandate rule / law of the case; government must show exceptional circumstances to revisit (it did not)
Whether the parties’ Settlement Agreement remains an enforceable contract despite the Federal Circuit’s reversal of the settlement approval	Plaintiffs: settlement is a binding contract; only allocation may need adjustment consistent with the mandate	United States: sought to withdraw and relitigate liability after remand (citing Kaseburg)	Court: settlement is a binding, final contract; change of position or intervening rulings do not void it; enforceable except that allocation must comply with Federal Circuit’s remand directions
Effect of Kaseburg (related district-court rulings about ownership/scope) on this case and on enforceability of the settlement	Plaintiffs: Kaseburg is not binding, came later, and does not undermine this court’s prior rulings or the settlement	United States: Kaseburg supports revisiting ownership/liability for some class members	Held: Kaseburg is not binding here, raises jurisdictional and substantive questions, and does not defeat the Settlement Agreement or preclude application of the law of the case
Proper next steps to implement the Federal Circuit remand (disclosure and allocation)	Plaintiffs: provide new notice and allow class members to verify allocations; mediate reallocation of the agreed fund	United States: sought briefing and summary judgment on liability issues instead of enforcement/mediation	Court: ordered disclosure was adequate; directed parties to attempt renewed mediation to reallocate fixed fund; denied government’s motions and granted plaintiffs’ motion to enforce settlement (allocation only to be revisited)

Key Cases Cited

Engel Indus., Inc. v. Lockformer Co., 166 F.3d 1379 (Fed. Cir.) (mandate rule scope — issues within prior judgment but not appealed are precluded)
Tronzo v. Biomet, Inc., 236 F.3d 1342 (Fed. Cir.) (law of the case and limited circumstances for reconsideration)
Ehrheart v. Verizon Wireless, 609 F.3d 590 (3d Cir.) (class settlement enforceable as contract; Rule 23(e) review does not negate contractual binding effect)
Whitlock v. FSL Mgmt., LLC, 843 F.3d 1084 (6th Cir.) (post‑settlement change in law does not permit escaping a binding class settlement)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S.) (summary judgment standard)