Ballagh v. Gray

50 Va. Cir. 12, 1999 Va. Cir. LEXIS 380
CourtBedford County Circuit Court
DecidedFebruary 2, 1999
DocketCase No. CH97018281-00
StatusPublished

This text of 50 Va. Cir. 12 (Ballagh v. Gray) is published on Counsel Stack Legal Research, covering Bedford County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ballagh v. Gray, 50 Va. Cir. 12, 1999 Va. Cir. LEXIS 380 (Va. Super. Ct. 1999).

Opinion

BY JUDGE JAMES W. UPDIKE, JR.

The captioned matter is presently before the court on the report of the commissioner, the exhibits introduced, the commissioner’s examination of the property and the records in the clerk’s office of this court, the memoranda and oral arguments submitted by counsel, the exceptions filed by the plaintiffs to the commissioner’s report, and the defendants’ response to plaintiffs’ exceptions.

The weight to be accorded a commissioner’s report is set forth in the Code of Virginia as follows:

The report of a commissioner in chancery shall not have the weight given to the verdict of a jury on conflicting evidence, but the court shall confirm or reject such report in whole or in part, according to the view which it entertains of the law and the evidence.

Section 8.01-610 of the Code of Virginia of 1950, as amended.

In this same regard, the Supreme Court of Virginia has stated:

[13]*13While the report of a commissioner in chancery does not carry the weight of a jury’s verdict... it should be sustained unless the trial court concludes that the commissioner’s findings are not supported by the evidence .... This rule applies with particular force to a commissioner’s findings of fact based upon evidence taken in his presence ... but is not applicable to pure conclusions of law contained in the report.

Hill v. Hill, 227 Va. 569, 576-77, 318 S.E.2d 292 (1984) (citations omitted).

The plaintiffs requested in their amended motion for declaratoiy judgment an order declaring them owners of “the dominant estate to an easement for ingress and egress over the estate of the defendants and declaring that the defendants’ land is servient to the estate of plaintiffs.” The defendants admitted that there is a public right-of-way leading from Virginia Secondary Route 703 to plaintiffs’ property. Consequently, the issue submitted for determination by the commissioner was the issue of the width of this right-of-way.

When making his determination, the commissioner first interpreted and applied § 33.1-184 of the Code of Virginia, which provides in pertinent part:

When a way has been worked by road officials as a public road and is used by the public as such, proof of these facts shall be prima facie evidence that the same is a public road. And when a way has been regularly or periodically worked by road officials as a public road and used by the public as such continuously for a period of twenty years, proof of these facts shall be conclusive evidence that the same is a public road. In all such cases the center of the general line of passage, conforming to the ancient landmarks where such exist, shall be presumed to be the center of the way and in the absence of proof to the contrary the width shall be presumed to be thirty feet.

Section 33.1-184 of the Code of Virginia.

Though §33.1-184 provides that any way that qualifies under its provisions as a public road is presumed to be thirty feet in width, the commissioner ruled this presumption to be a rebuttable presumption. Specifically, the commissioner ruled:

The provision cited above that “absent proof to the contrary” means the presumption provided in the statute is rebuttable. The commissioner’s view taken of the roadway clearly indicated that the [14]*14roadway, as used, did not exceed sixteen feet in width. There was no evidence presented by either plaintiffs or defendants as to the use of the roadway which dictates a width greater than sixteen feet. The roadway was bordered by old fences, brush and small trees, as well as stumps and other indicators, establishing that the use of the roadway was no greater than sixteen feet. Therefore, your commissioner finds that under § 33.1-184 of the Code of Virginia, 1950, as amended, the defendants have rebutted the presumption that the roadway was any greater than sixteen feet in width for its length.

(Com. Rep. pp. 2, 3.)

Upon my review of § 33.1-184, the exhibits that were introduced, and the cases cited by counsel, it is my opinion that the commissioner correctly interpreted and applied § 33.1-184, and that his finding of a sixteen foot right-of-way is supported by the evidence.

The commissioner then interpreted and applied § 15.2-2265 of the Code of Virginia (formerly § 15.1-478), which provides in pertinent part:

The recordation of a plat shall operate to transfer, in fee simple, to the respective localities in which the land lies the portion of the premises platted as is on the plat set apart for streets, alleys, or other public use and to transfer to the locality any easement indicated on the plat to create a public right of passage over the land.

Section 15.2-2265 of the Code of Virginia.

Section 15.2-2265 further provides in pertinent part: “Nothing contained in this article shall affect any right of a subdivider of land heretofore validly reserved.” The commissioner interpreted this language of reservation to allow a person when recording a plat to reserve a parcel from statutory dedication to the public. The commissioner then concluded: “In the instant case, the persons recording the plats clearly indicate on the face of the said plats that it is not their intent to convey any public roadway to the county.” (Com. Rep. p. 3.)

The plaintiffs except to this ruling of the commissioner and cite as authority Burns v. Board of Supervisors, 226 Va. 506, 312 S.E.2d 731 (1984). Plaintiffs interpret Burns to mean that § 15.2-2265 “would have and take precedence over any reservation of rights appearing on the plat.” (Def's. Memo., p. 2.)

I disagree with plaintiffs’ interpretation of Burns. Instead, I agree with the commissioner that the effect of Bums is to nullify an attempted reservation of [15]*15ownership in utility lines within a dedicated street. The Supreme Court specifically stated in this regard:

We conclude that Code § 15.1-478 precluded the dedicators from reserving, by implication, any ownership in this line. Public policy, as expressed in the language of the statute, requires that the local governing body have, to the greatest possible extent, dominion and control over its streets free and clear of the claims of developers. The purpose of Code § 15.1-478 is to require complete dedication of streets in order to enable the local governing body, in the exercise of its police power, to promote the public welfare.

226 Va. at 515 (emphasis added).

I therefore do not interpret Burns as precluding reservation of private rights when recording a plat. Rather, Burns, in my opinion, precludes partial reservation of private rights within a dedicated right-of-way. If there is statutory dedication of an easement to the public pursuant to § 15.2-2265, then such dedication is complete. If there is effective reservation of the way as a private easement, there is no statutory dedication of that easement to the public. Essentially, as to the recordation of a plat, an easement is either statutorily dedicated to the public, or it is reserved to the property owner as a private right-of-way, but not both.

I find further support for this position in

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Related

Hurd v. Watkins
385 S.E.2d 878 (Supreme Court of Virginia, 1989)
Burns v. BOARD OF SUP'RS OF STAFFORD COUNTY
312 S.E.2d 731 (Supreme Court of Virginia, 1984)
Hill v. Hill
318 S.E.2d 292 (Supreme Court of Virginia, 1984)
Burns v. Board of Supervisors
226 Va. 506 (Supreme Court of Virginia, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
50 Va. Cir. 12, 1999 Va. Cir. LEXIS 380, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ballagh-v-gray-vaccbedford-1999.