3:20-cv-00232
Alaska Railroad Corp v. Flying Crown Subdivision Addition No 1 Addition No 2 Property Owners Association
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Alaska Railroad Corporation (Alaska)
- Defendant: Flying Crown Subdivision Addition No. 1 and Addition No. 2 Property Owners Association, A NON-PROFIT (Alaska)
- Plaintiff’s Counsel: Oles Morrison Rinker & Baker LLP
- Case Identification: 3:20-cv-00232, D. Alaska, 09/21/2020
- Venue Allegations: Venue is asserted to be proper in the District of Alaska because the federally granted railroad right-of-way that is the subject of the action is located within the district.
- Core Dispute: This is a quiet title action in which Plaintiff seeks a judicial declaration regarding the scope of its railroad right-of-way over Defendant's property, as originating from federal law and land grants. No patent infringement is alleged.
- Technical Context: The dispute centers on the legal interpretation of rights associated with a railroad right-of-way, a critical asset for the safe and economic operation of freight and passenger rail services in Alaska.
- Key Procedural History: The complaint states the action was prompted by an October 23, 2019 letter from the Defendant demanding that Plaintiff relinquish any claim to "exclusive use" of the right-of-way. The complaint also cites a 2015 decision by the U.S. Department of the Interior's Board of Land Appeals, which interpreted the Alaska Railroad Transfer Act as requiring the conveyance of, at minimum, an "exclusive use easement" to the state.
Case Timeline
| Date | Event |
|---|---|
| 1914-03-12 | Congress passes the Alaska Railroad Act. |
| 1915 | U.S. federal government begins construction of the Alaska Railroad. |
| 1923-07 | President Harding drives the "golden spike" for the Alaska Railroad. |
| 1950-02-15 | U.S. issues Federal Land Patent #1128320 to Defendant's predecessor in interest. |
| 1981-07-07 | Alaska Railroad Transfer Act (ARTA) is introduced in the U.S. Senate. |
| 1983-01-14 | ARTA goes into effect, transferring the Alaska Railroad to the state of Alaska. |
| 2015 | U.S. Department of the Interior's Board of Land Appeals issues a decision related to ARTA. |
| 2019-10-23 | Plaintiff receives a letter from Defendant demanding relinquishment of exclusive use rights. |
| 2020-09-21 | Complaint filed. |
(Note: The provided complaint is a quiet title action concerning a real property right-of-way and does not allege infringement of any U.S. utility, design, or plant patent. The term "Patent" in the complaint refers to a Federal Land Patent, a real property instrument. Accordingly, the following sections concerning patent infringement analysis are not applicable and have been omitted as per the prompt instructions.)
No probative visual evidence provided in complaint.
II. Analyst’s Conclusion: Key Questions for the Case
This case does not involve patent infringement but instead presents fundamental questions of federal property and statutory law. The resolution will likely depend on the court's interpretation of historical land grants and congressional acts. The key questions are:
A core issue will be one of statutory interpretation: Did the Alaska Railroad Transfer Act of 1982 (ARTA) grant the state of Alaska, and subsequently the Plaintiff, an "exclusive use easement" over lands previously conveyed by the federal government, such as the land patented to Defendant's predecessor? The court will need to determine the precise nature and scope of the interest Congress intended to transfer to ensure the "safe and economic operation of the railroad" (Compl. ¶ 13).
A second key issue will be the interpretation of reserved rights: What is the scope of the interest reserved by the U.S. government in the 1950 Federal Land Patent #1128320, which reserved "a right of way for the construction of railroads, telegraph and telephone lines"? (Compl. ¶ 19). The court will likely examine whether this reservation implies the level of exclusive control characteristic of railroad rights-of-way, as argued by Plaintiff, or a more limited, non-exclusive easement.