The Iowa Supreme Court reversed lower court rulings in a closely watched case involving the authority of drainage districts to require railroad infrastructure modifications, ruling unanimously that Floyd County Board of Supervisors and Cerro Gordo County Board of Supervisors, acting as trustees for Joint Drainage District Nos. 6 and 56, can compel Iowa Northern Railway Company to install a culvert through its embankment.
The court issued its decision Dec. 19 in *Iowa Northern Railway Company v. Floyd County Board of Supervisors and Cerro Gordo County Board of Supervisors*, reversing both the Iowa Court of Appeals and the district court. Justice McDermott delivered the opinion, in which all justices joined, vacating the Court of Appeals decision and remanding the case to the district court.
The dispute centers on the joint drainage district's requirement that Iowa Northern Railway install a 5.5-foot diameter steel pipe culvert through an embankment supporting one of its rail lines. The drainage district, representing Floyd and Cerro Gordo counties, sought the modification as part of its water management responsibilities for agricultural land in the area.
Drainage districts operate as special governmental entities that manage water drainage in specific areas to enable more productive farmland use, the court noted. These districts possess statutory authority under Iowa law to modify infrastructure when necessary for proper water flow and drainage management.
Iowa Northern Railway challenged the requirement, filing suit to block the project. The railroad argued that federal railroad law preempts state drainage law and prohibits drainage districts from compelling such infrastructure modifications. The company contended that forcing the culvert installation would interfere with federal railroad operations and safety requirements.
The Iowa District Court for Floyd County, presided over by Judge Colleen Weiland, initially sided with the railroad. The district court concluded that installing the required culvert would jeopardize the rail line's operation and that the drainage district's authority under state law was preempted by federal railroad regulations. The court issued a writ of mandamus prohibiting the drainage district from requiring the culvert construction.
The Iowa Court of Appeals affirmed the district court's decision, agreeing that federal preemption principles protected the railroad from the state-mandated infrastructure modification. The appeals court upheld the writ of mandamus, maintaining that federal railroad law superseded the drainage district's state-law authority.
However, the Iowa Supreme Court reached the opposite conclusion after granting the drainage district's application for further review. The high court's unanimous reversal suggests the justices found the lower courts' preemption analysis flawed or overly broad in scope.
The case represents a significant clash between state drainage law and federal railroad regulations. Drainage districts across Iowa rely on their statutory authority to compel infrastructure modifications when necessary for proper water management. Agricultural interests often depend on these districts to prevent flooding and maintain productive farmland through effective drainage systems.
Railroad companies, meanwhile, operate under extensive federal oversight and safety regulations. They frequently argue that state and local requirements for infrastructure modifications can conflict with federal mandates and compromise operational safety or efficiency.
The Supreme Court's decision appears to limit the scope of federal preemption in this context, suggesting that drainage district authority under state law can coexist with federal railroad regulations in certain circumstances. The ruling may establish important precedent for future disputes between drainage districts and railroad companies throughout Iowa.
The case was argued by Robert W. Goodwin of Goodwin Law Office, P.C., in Ames, representing the appellants Floyd County and Cerro Gordo County boards of supervisors. Kimberly P. Knoshaug of Lewis, Webster, Van Winkle & Knoshaug, L.L.P., in Des Moines, argued for Iowa Northern Railway Company.
The Supreme Court's decision to vacate the Court of Appeals ruling and reverse the district court judgment sends the case back to the trial court for further proceedings consistent with the high court's opinion. The remand suggests additional factual or legal determinations may be necessary to resolve the specific requirements for culvert installation.
The ruling could have broader implications for agricultural drainage projects across Iowa, where conflicts between drainage districts and railroad infrastructure are not uncommon. The decision may clarify the circumstances under which state drainage law authority can override federal preemption claims in the railroad context.
Iowa Northern Railway Company now faces the prospect of complying with the drainage district's culvert installation requirement, subject to whatever specific terms and conditions the district court establishes on remand. The 5.5-foot diameter steel pipe culvert represents a substantial infrastructure modification that will require coordination between the railroad and drainage district to ensure proper installation and ongoing maintenance.