National Railroad Passenger Corp. v. McDonald
978 F. Supp. 2d 215
S.D.N.Y.2013Background
- Amtrak owns several small parcels along the Bronx River (the "Amtrak Bronx Rail Property") conveyed to it through the federal Rail Act and operates in the Northeast Corridor; the United States holds a federal mortgage interest in Amtrak property but Amtrak is not a federal agency.
- New York State, via NYSDOT and Commissioner Joan McDonald, pursued the Bronx River Greenway project and initiated EDPL eminent-domain proceedings; six parcels (105, 107, 108, 109, 110, 111) were appropriated and title vested in the State in February 2008; Parcel 178 remains at an earlier EDPL stage.
- Amtrak knew of the public hearing (May 2005) and received related communications from NYSDOT, but did not challenge the EDPL Determination and Findings in state court within the 30-day window provided by EDPL §207.
- Amtrak offered to sell the six condemned parcels to the State for the same amount the State had deposited as compensation; the State deposited funds in escrow under EDPL procedures which remain available.
- Amtrak filed this federal suit in April 2012 seeking declaratory and injunctive relief that federal law (Rail Act, RPSA, federal mortgage interest) preempts the State takings and that the takings are null and void; the parties cross-moved for summary judgment.
- The district court concluded the case largely on jurisdictional/procedural grounds: Eleventh Amendment bars Amtrak's claims regarding the six parcels already vested in the State; Parcel 178 claims are time-barred and Younger abstention is inappropriate because no Article 4 proceeding was pending.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal preemption / Supremacy Clause prevents NYSDOT condemnation of Amtrak parcels | Amtrak: Rail Act, RPSA, and federal mortgage interest preempt state eminent domain; takings are null and void | McDonald: State law appropriation valid; NYSDOT followed EDPL and has sovereign immunity | Court: Preemption claim as to already-condemned parcels is barred by Eleventh Amendment (retroactive relief); alternative statute-of-limitations bar for Parcel 178 |
| Whether Ex parte Young permits relief against the NYSDOT Commissioner for the six condemned parcels | Amtrak: seeks declaratory and injunctive relief; claims ongoing/future interference so Ex parte Young applies | McDonald: relief sought is retrospective because title has vested; sovereign immunity applies | Court: Ex parte Young does not apply — relief would be retrospective (return of property) and is barred under Eleventh Amendment (Knight/Edelman line) |
| Whether Younger abstention requires dismissal regarding Parcel 178 | Amtrak: seeks federal decision; Younger not applicable | McDonald: federal court should abstain because EDPL is state process and important state interests are implicated | Court: Younger inapplicable — no ongoing Article 4 judicial proceeding at filing; EDPL process is unitary but no pending judicial stage for Parcel 178 |
| Whether Amtrak's claims re: Parcel 178 are time-barred | Amtrak: alleged defects in notice; continuing violation tolls limitations | McDonald: claims accrued when Determination and Findings published; six-year limitations applies | Court: Claims accrued by publication (Aug 2005); six-year limitations expired before suit (filed Apr 2012); continuing-violation theory rejected |
Key Cases Cited
- Ex parte Young, 209 U.S. 123 (1908) (allows prospective injunctive relief against state officers for ongoing federal-law violations)
- Edelman v. Jordan, 415 U.S. 651 (1974) (equitable restitution from state treasury is barred by Eleventh Amendment when relief is retrospective)
- Green v. Mansour, 474 U.S. 64 (1985) (declaratory relief that only addresses past violations is barred by Eleventh Amendment)
- Larson v. Domestic & Foreign Commerce Corp., 337 U.S. 682 (1949) (suit against officials permitted for ultra vires acts but footnote limits relief that requires affirmative action by sovereign)
- Knight v. New York, 443 F.2d 415 (2d Cir. 1971) (in Second Circuit, post-taking suits seeking return of property are barred by Eleventh Amendment; relief must have been sought pre-taking)
- Verizon Maryland Inc. v. Pub. Serv. Comm'n, 535 U.S. 635 (2002) (Ex parte Young inquiry focuses on whether relief is prospective and addresses ongoing violations)