Wolfe v. Reading Blue Mountain (majority)
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Gary and Mary Wolfe own property in Muhlenberg Township, which includes a roofing business and several rental homes. Reading Blue Mountain and Northern Railroad Company (RBMN) sought to condemn a portion of the Wolfes' property to reestablish a rail siding to serve Russell Standard, an asphalt company. The Wolfes objected, arguing the taking was for a private benefit rather than a public purpose.
The Berks County Court of Common Pleas sustained the Wolfes' objections, finding the condemnation was intended solely to benefit Russell Standard and not the public. The court noted that the rail siding would disrupt the Wolfes' property and existing businesses, and that Russell Standard could use its own property for the rail connection. RBMN's refusal to consider alternative routes further indicated a private benefit.
The Commonwealth Court reversed, relying on older case law that generally supported railroad takings for public use. The panel presumed RBMN's taking was for a public purpose, emphasizing the historical importance of railroads in serving public needs.
The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision. The Court held that the taking did not serve a public purpose as required by the Constitution. The Court emphasized that the public must be the primary and paramount beneficiary of the taking, which was not demonstrated in this case. The evidence showed the taking primarily benefited Russell Standard, with no significant public advantage. The Court remanded the case for reinstatement of the trial court's order dismissing the condemnation action.
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