Great Northern Railway Co. v. Minnesota Ex Rel. Village of Clara City

Background

A village in Minnesota (Clara City) sought to force three railroad companies to build a sidewalk on the south side of Bunde Street where the railroad right of way crosses that street. The right of way is 300 feet wide with three tracks near the center. Business buildings line both sides and people cross the tracks frequently. The track area was already planked for crossing, but the village asked the courts to require an added sidewalk across the railroad right of way to connect with sidewalks on either side of the street.

Reasoning

The core question was whether Minnesota could constitutionally require the railroads to construct such a sidewalk. The Court relied on long-established authority that states may, in the public interest, require railroads to make street crossings reasonably safe and convenient and that railroads accept franchise duties subject to reasonable safety rules. The Minnesota Supreme Court had interpreted a 1913 amendment to require a sidewalk connecting with municipal or abutting walks, and it explained why a separate pedestrian way promotes safety — avoiding places where pedestrians and many vehicles mingle, preventing unexpected crossings, and reducing mud or unsafe conditions. The Court found the statute to be a reasonable exercise of the State’s power over public safety and not an arbitrary burden on the railroads, and it affirmed the state court judgment requiring construction at the railroad’s expense.

Real world impact

Railroad companies can be required to build sidewalks over their legitimate right of way to match and connect with town sidewalks, improving pedestrian safety at street-track crossings. The rule places construction and maintenance responsibility on the railroad where the statute applies, and it rests on the State’s authority to protect public safety.