Union Pacific R. Co. v. Laramie Stock Yards Co. - 231 U.S. 190 (1913)
U.S. Supreme Court
Union Pacific R. Co. v. Laramie Stock Yards Co., 231 U.S. 190 (1913)
Union Pacific Railroad Company v.
Laramie Stock Yards Company
Submitted October 14, 1913
Decided December l, 1913
231 U.S. 190
The first rule of construction of statutes is that legislation is addressed to the future, and not to the past. This rule is one of obvious justice.
Unless its terms unequivocally import that it was the manifest intent of the legislature enacting it, a retrospective operation will not be given to a statute which interferes with antecedent rights or by which human action is regulated.
The right of way granted under the Land Grant Act of July 1, 1862, was a very important aid to the railroad, and was a present absolute grant subject to no conditions except those absolutely implied, such as construction and user.
The Act of June 24, 1912, c. 181, 37 Stat. 138, permitting state statutes of limitation to apply to adverse possession of portions of the right of way granted to the railroad company under the Act of July 1, 1862, did not have a retroactive effect. Sohn v. Waterson, 17 Wall. 596.
Congress did not intend, by the Act of June 24, 1912, to exercise powers to alter and amend the charters of the railroad companies reserved by the Acts of July 1, 1862, and July 2, 1864.
This Court will not assume that Congress intends to forfeit or limit any of the rights granted to the transcontinental railroads unless it does so explicitly.
An amendment to an existing charter enacted under the reserved power to alter and amend will not be construed as having a retroactive effect as to vested property rights in absence of clear intent of the legislature enacting it.
The facts, which involve the construction and application of the Union Pacific Land Grant Act of July 1, 1862, the Act of June 24, 1912, and the extent of rights claimed to have been acquired under the latter act by adverse possession in the railroad right of way, are stated in the opinion.