Miami County Board of Commissioners v. Kanza Rail-Trails Conservancy, Inc.
255 P.3d 1186
| Kan. | 2011Background
- This is the Kansas Supreme Court's 2011 decision in Miami County Board of Commissioners v. Kanza Rail-Trails Conservancy, Inc., No. 101,811.
- The case involves 4.5 miles of railbanked railroad right-of-way in Miami County converted to a recreational trail under the federal Rails-to-Trails Act (Trails Act) and Kansas KRTA.
- KRTA imposes duties on a nongovernmental “responsible party” for trail maintenance, safety, and related costs, including a bond or escrow to cover annual costs.
- Missouri Pacific abandoned the line; RTC and Seranata handled interim use, then Kansas Horseman Foundation, now Kanza Rail-Trails Conservancy, became the current trail operator and “responsible party.”
- Miami County sought a writ of mandamus to compel posting a bond (later determined to be $9,040); the district court held KRTA not preempted and approved the bond amount.
- The Supreme Court affirmed, upholding the bond requirement and the district court’s determinations about KRTA duties and costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether KRTA is preempted by the Trails Act (16 U.S.C. §1247(d)) | Kanza argues KRTA conflicts with and is preempted by the Trails Act | Miami County argues KRTA is a valid state regulation that does not obstruct federal goals | KRTA is not preempted under the Trails Act |
| Whether KRTA violates the Dormant Commerce Clause | Kanza asserts KRTA discriminates against rail-trails and inter-state interests | County contends no in-state vs. out-of-state discrimination and no undue burden | KRTA does not discriminate against interstate commerce and is rationally related to safety/land-use aims |
| Whether KRTA violates Equal Protection | Kanza asserts KRTA creates unequal treatment of rail-trails vs. other trails | KRTA rationally distinguishes rail-trails to preserve right-of-way and protect landowners | KRTA passes rational-basis review; no equal-protection violation |
| Whether the district court had jurisdiction to set the bond amount | Kanza contends court lacked authority without an agreed bond amount | Miami County argues statute authorizes court to decide bond/escrow and enforce compliance | District court had jurisdiction; bond amount of $9,040 was appropriate and enforceable |
| Whether mandamus was proper to compel posting of bond | Mandamus was proper to interpret and enforce KRTA duties |
Key Cases Cited
- Preseault v. ICC, 494 U.S. 1 (U.S. 1990) (railbanking and rail-trail purpose; federal supremacy over railroad rights-of-way)
- English v. General Electric Co., 496 U.S. 72 (U.S. 1990) (implied preemption framework; field vs. conflict preemption)
- Hillsborough County v. Automated Medical Labs., Inc., 471 U.S. 707 (U.S. 1985) (conflict preemption analysis framework)
- Amerada Hess Corp. v. N.J. Taxation Div., 490 U.S. 66 (U.S. 1989) (dormant Commerce Clause – discriminatory intent/effect framework)
- Department of Revenue of Kentucky v. Davis, 553 U.S. 328 (U.S. 2008) (two-step dormant Commerce Clause scrutiny (discrimination then balancing))
- Dean Milk Co. v. Madison, 340 U.S. 349 (U.S. 1951) (absent discriminatory effect; Madison ordinance struck for burden on interstate commerce)
- In re Tax Appeals of CIG Field Services Co., 279 Kan. 857 (Kan. 2005) (dormant Commerce Clause; discrimination analysis under Kansas)
- Jones v. Kansas State University, 279 Kan. 128 (Kan. 2005) (legislative intent and statutory interpretation principles)
- State ex rel. Morrison v. Oshman Sporting Goods Co., 275 Kan. 763 (Kan. 2003) (statutory interpretation guidance)