Hardin County Drainage District 55, Division 3, Lateral 10 v. Union Pacific Railroad Company, 826 N.W.2d 507

Hardin County Drainage District 55 sues Union Pacific Railroad for costs to replace a century-old subterranean drainage tile under UP’s roadbed.
Tile installed circa 1914 serves 560–580 acres, draining surface and subsurface water; located 6.62 feet below the west ditch and not visible from surface.
In 2007 UP repaired the roadbed and ballast, which plugged the tile and caused farmland flooding; district issued statutory notice to rebuild under Iowa Code § 468.109.
District replaced the existing 14-inch tile with a 21-inch carrier pipe inside a 28-inch steel carrier pipe; UP did not object but disputed statutory obligation to pay.
District court awarded damages for construction costs, permit fees, surveying/engineering, administration, crop loss, and attorney fees; UP appealed.
Iowa Supreme Court reversed, holding the drainage tile is not a culvert under § 468.111, so UP is not responsible; case remanded for dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the underground drainage tile a culvert under ch. 468?	Hardin County argues the tile is a culvert and UP must pay.	Union Pacific contends the tile is not a culvert, so not statutorily obligated.	Tile not a culvert; UP not liable.
If it were a culvert, is it on a natural waterway or at a place chosen by the railroad?	Hardin County would argue cost to be borne by UP if not at natural waterway/place chosen by railroad.	UP would argue costs should follow the statute’s allocation when culvert is involved.	Not reached/necessary because tile is not a culvert.

Chicago Cent. & Pac. R.R. v. Bd. of Supervisors, 194 N.W.266 (Iowa 1923) (culvert/bridge cost allocation under drainage statute)
Chi., Cent. & Pac. R.R. v. Calhoun Cnty. Bd. of Supervisors, 816 N.W.2d 367 (Iowa 2012) (statutory interpretation of drainage culvert issues)
Hinkle v. Chi., R.I. & P. Ry., 227 N.W.419 (Iowa 1929) (waters brought upon area not due to defendant; not responsible)
Chi. & N.W. Transp. Co. v. Webster Cnty. Bd. of Supervisors, 880 F. Supp. 1290 (N.D. Iowa 1995) (federal district court on railroad crossing costs)
Chi., R.I. & P. Ry. v. Bd. of Supervisors, 194 N.W. 266 (Iowa 1923) (initial framework for culvert/bridge cost responsibilities)
Mosquito Drainage Dist. v. Chi., M. & St. P. Ry., 190 Iowa 162 (Iowa 1920) (statutory aims to drain agricultural lands; district responsibility)
State v. McCullah, 787 N.W.2d 90 (Iowa 2010) (statutory construction principles and legislative intent)