Northern Pacific Railway Co. v. Ely

Background

A railroad company sued many local property owners in Spokane County to quiet title and recover possession of a 400-foot strip claimed as its right of way. The defendants held patents from the United States under preemption and homestead laws and had occupied, improved, and paid assessments on these lots for ten to nearly twenty years. The Washington state courts ruled for the local owners, saying their long, uninterrupted possession and improvements gave them title.

Reasoning

The Supreme Court reviewed whether private individuals could acquire title by long possession to land granted by Congress as a railroad right of way. The Court relied on its earlier decision in Northern Pacific Railway Company v. Townsend, which held that individuals may not gain title by adverse possession to a federally granted railroad right of way. Applying that rule, the Court reversed the state supreme court’s judgment and said the railroad’s federal grant could not be defeated by adverse private occupancy in the way the state had held.

Real world impact

The Court’s decision lets the railroad press its claim against those who had thought their long use gave them title. The opinion also notes that Congress later passed a law validating past conveyances while narrowing the effective right of way to 100 feet on each side of the track, and that the railroad accepted that law. The case was sent back to state courts for further proceedings consistent with the Court’s ruling and the later federal statute.

Dissents or concurrances

Justice Harlan dissented, believing the state court’s decision should have been affirmed for the reasons he gave.