Atlantic Coast Line Railroad v. City of Goldsboro

Background

A long-established railroad owns a 130-foot strip through what became the City of Goldsboro. The railroad built its tracks before the town was laid out, and the unused parts of the strip have long been used as the city’s main business street. The city passed ordinances restricting car shifting on four central blocks, banning cars from standing more than five minutes there, and requiring tracks to be lowered and filled to match street grade.

Reasoning

The main question was whether these rules unlawfully impaired the railroad’s charter or took its property without fair legal process. The Court accepted the state court’s factual findings that the street is crowded, that trains and multiple rail lines make crossings dangerous, and that the railroad long acquiesced to public street use. It held the measures are reasonable public-safety and drainage rules, fairly related to protecting the public, and do not unnecessarily interfere with the railroad’s operations or its contract and property rights.

Real world impact

The decision lets the city limit when and how the railroad can shift cars in the busiest downtown blocks, requires loading and unloading to be moved to terminals, and permits the city to change track grades and fill between rails for safety and drainage. Those changes affect how the railroad and local industries organize freight movements and street use going forward.