Murray v. Dep’t of Conservation & Recreation

Plaintiffs filed an action to quiet title, alleging that a railroad easement formerly owned by the Pennsylvania Central Transportation Co. across portions of their lands was abandoned by the United States Railway Association by virtue of its non designation for transfer to the Consolidated Rail Corporation in a final plan system. The land court dismissed without prejudice Plaintiffs’ action for lack of subject matter jurisdiction, concluding that a certificate of abandonment from the Federal Surface Transportation Board (STB) was necessary before a state court could exercise jurisdiction to determine state law claims regarding easements and that STB’s jurisdiction was exclusive and primary. The Supreme Judicial Court affirmed, holding that the land court did not err in determining that the question of abandonment in this case remained in the exclusive jurisdiction of the federal government and, therefore, the land court did not have subject matter jurisdiction over Plaintiffs’ action. View "Murray v. Dep’t of Conservation & Recreation" on Justia Law