## Facts

- Conrail held a railroad right-of-way in Armstrong County, Pennsylvania.
- Conrail obtained federal authorization to abandon rail service on the line.
- After receiving abandonment authority, Conrail arranged to convey the corridor to a trail entity through an intermediary; the Allegheny Valley Land Trust (AVLT) became the grantee.
- Conrail conveyed the corridor to AVLT by quitclaim deed containing a declaration that the corridor was railbanked: preserved for possible future rail use with interim recreational trail use.
- Adjacent landowners sued, alleging the railroad easement had been abandoned and the corridor had reverted to them under state property law.
- The landowners also asserted that maintaining the corridor for trail use under railbanking effected a taking without just compensation.

## Issues

1. Whether a railroad right-of-way is validly railbanked under § 1247(d) of the National Trails System Act when rail service has ceased and the corridor is conveyed for interim trail use, even if the carrier does not commit to restoring rail service.
2. Whether, given federal railbanking, Pennsylvania state-law abandonment and reversion doctrines can terminate the railroad easement and vest title in the adjacent landowners.
3. Whether the asserted railbanking/trail use theory supports declaratory relief in state court based on an alleged taking without just compensation.

## Decision

- The Supreme Court of Pennsylvania affirmed the Superior Court’s reversal of the trial court.
- The court held that, if § 1247(d) requirements are met, the corridor is railbanked regardless of whether the rail operator agrees to resume service.
- Because the corridor was railbanked, it was not abandoned for state property-law purposes, and state-law reversionary interests did not vest.
- The trial court erred by concluding the easement was terminated and the corridor reverted to the adjoining landowners.

## Legal Principles

- Under § 1247(d) of the National Trails System Act, compliance with federal railbanking procedures preserves a railroad corridor for possible future rail use while permitting interim recreational trail use.
- A properly railbanked corridor is not “abandoned” for purposes of state property law, notwithstanding cessation of rail operations.
- Federal railbanking precludes application of state-law abandonment doctrines that would otherwise terminate a railroad easement and trigger reversion to servient estate owners.
- Under Pennsylvania law, abandonment generally requires nonuse plus intent to abandon; participation in railbanking is inconsistent with an intent to abandon the corridor outright.
- State-law ownership/reversion disputes are distinct from potential compensation claims; the court’s task was limited to whether abandonment and reversion occurred under applicable law.

## Conclusion

The court held that a railroad right-of-way transferred for interim trail use under a valid § 1247(d) railbanking arrangement is not abandoned under Pennsylvania property law, so adjacent landowners’ reversion claims fail while federal railbanking status persists.


Moody v. Allegheny Valley Land Tr., 976 A.2d 484 (Pa. 2009)