National R.R. Passenger Corp. v. McDonald

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Amtrak appealed from the district court's grant of summary judgment dismissing its federal Supremacy Clause claims filed against the Commissioner, claiming that the Supremacy Clause deprived the NYSDOT of authority to condemn Amtrak's property by eminent domain. The district court held that Amtrak's claims were barred under the Eleventh Amendment and, in the alternative, the claims were time-barred. The court concluded that, because one of the parcels of land is not subject to sovereign immunity, the statute of limitations issue must be resolved. Amtrak argued that it suffered two separate injuries: first, when it learned that NYSDOT planned to take its land, and second, when the Commissioner actually executed the takings. Under the circumstances of this case, the court concluded that Amtrak brought its federal claims more than six years afters its claims accrued. Accordingly, the court affirmed the judgment of the district court based on its alternative conclusion that the claims were time-barred. View "National R.R. Passenger Corp. v. McDonald" on Justia Law