This morning the Federal Circuit issued one precedential opinion in a Takings case. Here is the introduction.
Castillo v. United States (Precedential)
Reinaldo Castillo and others own plots of land abutting a railroad right-of-way that was long ago granted to, and for decades used by, the Florida East Coast Railway Co. in Dade County, Florida. It is undisputed before us that, when the railway company eventually abandoned the right-of-way for rail use (the purpose for which the right-of-way was granted), full rights to the underlying land—title unencumbered by the right-of-way easement—would have reverted to whoever owned such rights, had there been no overriding governmental action. But there was such governmental action: the railway company successfully petitioned a federal agency to have the railroad corridor turned into a recreational trail. The landowners sued the United States in the Court of Federal Claims, alleging that the agency’s conversion of the railroad right-of-way into a recreational trail constituted a taking of their rights in the corridor land abutting their properties and that the United States must pay just compensation for that taking. To establish their ownership of the corridor land, the plain- tiffs relied on a Florida-law doctrine known as the “center- line presumption,” which, where it applies, provides that when a road or other corridor forms the boundary of a landowner’s parcel, that landowner owns the fee interest in the abutting corridor land up to the corridor’s centerline, unless there is clear evidence to the contrary.
In proceedings on summary-judgment motions, the government argued that the landowners did not own the land to the centerline of the railroad corridor at issue. The trial court agreed with the government, holding that the only reasonable finding on the evidence in this case was that the centerline presumption was overcome or was inapplicable. See Castillo v. United States, 138 Fed. Cl. 707 (2018) (SJ Op.); Castillo v. United States, 140 Fed. Cl. 590 (2018) (Reconsideration Op.). The landowners appeal. We conclude that the trial court misapplied the centerline presumption to the evidence. We reverse and remand.