## Facts

- In 1871, landowners conveyed to a railroad (1) a 100-foot-wide right-of-way and (2) a separate adjoining strip described as conveyed “for depot and railroad purposes.”
- The depot/railroad strip was originally about 200 feet wide and 1000 feet long along the south side of the right-of-way.
- The plaintiffs later acquired town lots contiguous to the right-of-way and the depot/railroad strip.
- Penn Central, successor to the railroad’s interest, ceased operating rail service through the town and abandoned the right-of-way on November 30, 1973.
- After ending rail operations, Penn Central continued collecting rent from tenants occupying space on the depot/railroad strip.
- Plaintiffs sued to quiet title, arguing the railroad received only an easement limited to railroad purposes that terminated upon abandonment.

## Issues

1. Whether the 1871 deed conveyed the “depot and railroad purposes” strip in fee simple or granted only an easement limited to railroad-related use.
2. If the interest was an easement, whether abandonment of railroad operations extinguished that interest so that title should be quieted in the adjoining landowners.

## Decision

- The Supreme Court of Indiana granted transfer, vacated the Court of Appeals’ opinion, and reversed the trial court.
- The court held the 1871 deed conveyed only an easement in the “depot and railroad purposes” strip, not a fee simple estate.
- Because the easement was limited to railroad purposes, it terminated when Penn Central abandoned railroad operations.
- Title to the strip was quieted in favor of the adjoining landowners.

## Legal Principles

- Deed interpretation turns on the parties’ intent as expressed in the instrument as a whole.
- Conveyances to railroads that use purpose-limiting language (e.g., “for right-of-way,” “for railroad purposes,” or comparable formulations) are generally construed as granting an easement, absent clear language conveying a fee.
- A purpose-limited easement terminates when the specified purpose ends, including by abandonment of railroad use.
- Post-abandonment activities (such as leasing to tenants) do not change the estate created by the deed and do not revive an easement terminated by cessation of the authorized purpose.

## Conclusion

The Indiana Supreme Court concluded that the depot/railroad strip described “for depot and railroad purposes” was conveyed as an easement tied to railroad use; once the railroad was abandoned, the easement ended and the adjoining landowners were entitled to quiet title.


Brown v. Penn Cent. Corp., 510 N.E.2d 641 (Ind. 1987)