Takings, Property conveyance
Where the language of the deed is clear, under Florida law, no statute, policy, or fact can operate to convert an interest in fee simple for the purpose of running a railway to an easement.
http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/13-5098.Opinion.12-22-2015.1.PDF
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.