Allison C. Davis

ALLISON DAVIS is a nationally-recognized railroad regulatory lawyer with a distinguished background in government and a proven track record of helping clients navigate complex transportation issues. Drawing on more than a decade of experience at the Surface Transportation Board (STB), Allison provides strategic counsel to railroads and other stakeholders seeking to advance their business interests while maintaining regulatory compliance. Allison represents railroads before federal courts and federal agencies, such as the STB and the Federal Railroad Administration (FRA).

Allison also advises parties in transactions involving rail lines or other transportation assets, and counsels clients on compliance with federal transportation regulations. She has represented railroads in high-stakes mergers, stock and asset acquisitions, and licensing transactions before the STB. She counsels private infrastructure investors and rail carriers on a range of matters, including rail line discontinuances, leases, and operational transitions.

Prior to joining Sidley, Allison held several high-level positions at the STB, including as a senior advisor to two STB Chairmen, and eventually served as the Director of the Office of Proceedings. In that role, she led the STB’s largest staff office, supervised teams responsible for developing the public record in proceedings before the agency, and issued decisions pursuant to delegated authority. Allison led STB staff teams on numerous complex rulemakings, licensing cases, and adjudicatory proceedings, including multimillion dollar rate disputes and reasonable practice disputes. She provided legal and policy guidance to the Board on various aspects of STB law, including preemption, unreasonable rates, unreasonable practices, freight and passenger rail construction projects, and proposed transactions.

Representative matters that Allison has handled recently include:

Transactions and Licensing

• CN in acquisition of Iowa Northern Railway Company.
• Norfolk Southern Railway Company in acquisition of the Cincinnati Southern Railway rail line.
• FTAI Infrastructure, Inc. in its continuance in control of a shortline railroad.
• Gulf & Atlantic Railways, LLC in acquisition of various shortline railroads.
• Shortline railroads in STB licensing proceedings, including rail line purchases, lease acquisitions, and discontinuances.

Litigation and Regulatory Proceedings

• Successfully briefed a challenge to a reciprocal switching rule in the Seventh Circuit in Grand Trunk Corp. v. STB (2025).
• Secured a declaratory order from the STB on the jurisdictional status of rail track.
• A railroad in federal court litigation involving preemption under the ICC Termination Act (pending).
• A railroad in case involving request for terminal trackage rights (pending).
• A railroad in STB case involving request for declaratory order and injunctive relief relating to interruption of service due to maintenance work.
• Participated in regulatory hearing on growth in the freight rail industry before the STB.
• A rail carrier in investigation relating to the National Historic Preservation Act (pending).
• Class I railroad in STB proceeding opposing a proposal that would require railroads to pay delay charges for private car shipments (pending).
• Class I railroad in a STB rulemaking proceeding on reciprocal switching rules for inadequate service (pending).
• Rail carriers in FRA rulemaking proceeding concerning proposal to regulate the crew size of railroads (pending).
• A rail carrier in FRA rulemaking on track geometry inspections (pending).

• Association of Transportation Law Professionals