Chicago, Milwaukee & St. Paul Railway Co. v. City of Minneapolis

Background

A city (Minneapolis) and a railroad company (Chicago, Milwaukee & St. Paul Railway) disputed compensation after the city planned a public canal connecting nearby lakes that would cross the railroad’s right-of-way. The city acquired park shores and sought to condemn a 100-foot strip for the canal and walks. The canal would make an existing small watercourse and pipe useless and require the railroad to carry its tracks on a bridge across the new canal. The mere land taken was valued at $10; the city’s bridge plans cost about $18,513, while a basic railroad bridge would cost $15,969. The parties agreed the city would pay $2,544 for ornamental features, but the railroad sought full bridge costs and upkeep.

Reasoning

The Court asked whether denying the railroad reimbursement for constructing and maintaining the bridge violated the Fourteenth Amendment’s protection against depriving property without due process. Relying on prior decisions and Minnesota law, the Court explained that railroads take their charters subject to the state’s power to open public ways across rights-of-way. That power may require the railroad, without compensation, to provide suitable crossings for new public streets or waterways. The Court treated the canal and its walks as a public way and concluded requiring the railroad to bridge it was a legitimate exercise of state authority, not a constitutional taking.

Real world impact

The ruling means cities may create new public waterways or streets that cross existing tracks and lawfully require railroads to provide and maintain bridges without bearing full compensation. Railroads operating under state charters should expect obligations to adapt to later public improvements, and claims for full reimbursement of bridge construction may be denied.