Whether Grable-type subject matter jurisdiction exists where (A) it is undisputed that the Plaintiffs' state law cause of action for quiet title does not arise under federal law, and (B) the Plaintiffs do not challenge any aspect of the operation of the federal Trails Act or attempt to affect its ongoing viability in any manner whatsoever, but rather only raise the Trails Act in anticipation of a state law defense, thus there can be no 'substantial' federal interest involved

QUESTIONS PRESENTED 1. Whether Grable-type subject matter jurisdiction exists where (A) it is undisputed that the Plaintiffs’ state law cause of action for quiet title does not arise under federal law, and (B) the Plaintiffs do not challenge any aspect of the operation of the federal Trails Act or attempt to affect its ongoing viability in any manner whatsoever, but rather only raise the Trails Act in anticipation of a state law defense, thus there can be no “substantial” federal interest involved. 2. If the Court believes it has subject matter jurisdiction, then: Whether the Trails Act operates per se to preserve a pre-existing state law railroad purpose easement or whether the continuing existence of such easement depends upon the state law determination of whether trail use is beyond the scope of the easement and/ or whether the easement was abandoned under state law?