James Fredrick Miles v. Texas Central Railroad & Infrastructure, Inc. and Integrated Texas Logistics, Inc., 647 S.W.3d 613

Background

Texas Central Railroad & Infrastructure, Inc. (formed 2012, amended 2015) and Integrated Texas Logistics, Inc. (formed 2017) are private companies jointly pursuing a high-speed electric passenger rail between Houston and Dallas; their charters state purposes to construct, operate, and maintain interurban electric rail lines.
The companies conducted route surveys, spent substantial funds, signed consultant and connectivity agreements, and sought federal permits and rulemaking; petitioner James Miles owns ~600 acres on the preferred route and refused access for surveys.
Miles sued for a declaratory judgment that the companies lack eminent-domain authority; Texas Central counterclaimed that they qualify as (1) "interurban electric railway companies" under Tex. Transp. Code ch. 131 and (2) as "railroad companies" under Tex. Transp. Code §81.002.
The trial court granted summary judgment for Miles; the court of appeals reversed, holding the entities possess eminent-domain power under both statutory routes.
The Texas Supreme Court affirmed the court of appeals, holding the entities have eminent-domain authority under Chapter 131 and remanding other issues (e.g., fees); the Court did not reach whether the entities are "railroad companies."

Issues

Issue	Plaintiff's Argument (Miles)	Defendant's Argument (Texas Central Entities)	Held
1. Whether entities qualify as an "interurban electric railway company" with eminent-domain power under Tex. Transp. Code §131.011–.012	Chapter 131 contemplates obsolete, small streetcar/interurban operations from early 20th century and cannot be stretched to cover modern high-speed electric rail	§131's plain language covers a corporation chartered to conduct and operate an electric railway between municipalities for passenger transport, without speed/size limits	Held: Yes — §131's plain, unambiguous language covers the proposed high‑speed electric railway.
2. Whether Denbury requires an entity to show a "reasonable probability" the project will be completed/serve the public before obtaining eminent-domain power	Denbury requires objective evidence of a reasonable probability of success; otherwise condemning power could be abused by speculative actors	Denbury prevents mere "checking a box," but does not impose a blanket reasonable‑probability‑of‑completion test where the chartered purpose and ongoing activities exist	Held: No new, broad reasonable‑probability‑of‑completion test; Denbury forbids automatic acquisition by mere formality but does not bar entities that are properly chartered and actively pursuing the project.
3. Whether Texas Central Railroad’s failure to identify Chapter 131 in a 2012 comptroller letter caused expiration of any Chapter 131 authority under Gov’t Code §2206.101	The company failed to list Chapter 131 by Dec. 31, 2012, so any eminent‑domain authority expired on Sept. 1, 2013	§131 authority attaches only when a corporation is chartered for that statutory purpose; Texas Central amended its charter in 2015 to state the interurban purpose and thus acquired authority after 2012	Held: Authority under §131 did not expire in 2013 because Texas Central did not acquire §131 authority until it was chartered for that purpose in 2015.
4. Whether companies qualify as "railroad companies" (legal entity "operating a railroad") under Tex. Transp. Code §81.002	Not a railroad company because it does not yet own tracks, rolling stock, or presently operate trains	"Operating" can include constructing, maintaining, and preparing to run a railroad; ordinary meaning supports inclusion	Held: Not decided by the majority (Chief Justice Hecht concurred that they also qualify), because §131 holding was dispositive.

Key Cases Cited

Silguero v. CSL Plasma, Inc., 579 S.W.3d 53 (Tex. 2019) (statutory interpretation principles; use plain language and context).
Denbury Green Pipeline–Tex., LLC v. Texas Rice Land Partners, Ltd., 510 S.W.3d 909 (Tex. 2017) (Denbury II) (limits on acquiring condemnation power by mere assertions; need for objective evidence in some contexts).
Texas Rice Land Partners, Ltd. v. Denbury Green Pipeline–Tex., LLC, 363 S.W.3d 192 (Tex. 2012) (Denbury I) (common‑carrier/condemnation analysis; protection against condemnations for private use).
Coastal States Gas Producing Co. v. Pate, 309 S.W.2d 828 (Tex. 1958) (statutes granting eminent domain strictly construed in favor of landowners but given full meaning consistent with purpose).
San Antonio & A.P. Ry. Co. v. Southwest Tel. & Tel. Co., 55 S.W. 117 (Tex. 1900) (broad statutory language can embrace later‑developed technologies).
Facebook, Inc. v. Duguid, 141 S. Ct. 1163 (2021) (textualist canon: courts must respect statutory definitions and not rewrite them to reach new technologies).
Kyllo v. United States, 533 U.S. 27 (2001) (constitutional interpretation analogies regarding historical understanding of terms).
City of Garland v. Dallas Morning News, 22 S.W.3d 351 (Tex. 2000) (summary‑judgment cross‑motions standard).
City of Austin v. Whittington, 384 S.W.3d 766 (Tex. 2012) (judicial review available for fraudulent, bad‑faith, or arbitrary condemnations).
Entergy Gulf States, Inc. v. Summers, 282 S.W.3d 433 (Tex. 2009) (courts respect policy‑laden statutes as written).