Bay City Prop. Owners v. Cnty. Comm'rs of Queen Anne's

CourtCourt of Special Appeals of Maryland
DecidedOctober 2, 2024
Docket0034/23
StatusPublished

This text of Bay City Prop. Owners v. Cnty. Comm'rs of Queen Anne's (Bay City Prop. Owners v. Cnty. Comm'rs of Queen Anne's) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bay City Prop. Owners v. Cnty. Comm'rs of Queen Anne's, (Md. Ct. App. 2024).

Opinion

Bay City Property Owners Association, Inc. v. County Commissioners of Queen Anne’s County, et al. No. 0034, Sept. Term, 2023 Opinion by Leahy, J.

Adverse Possession > Nature and Requisites > Duration and Continuity of Possession > Continuity in general The requirement that adverse use be uninterrupted or continuous also does not mean that the use “must be exercised constantly and without any intermission”; rather, the requirement “may be satisfied by use ‘with such frequency and constancy as to affect the landowner with notice that it is being exercised[.]’” Zimmerman v. Summers, 24 Md. App. 100, 108 (1975) (quoting 4 Tiffany Real Prop. § 1202 (3d ed.)).

Easements > Creation, Existence, and Termination > Evidence > Presumptions and burden of proof In a quiet title action, the plaintiff initially bears the burden of proving possession and legal title to contested property. Wilkinson v. Bd. of Cnty. Comm’rs of St. Mary’s Cnty., 255 Md. App. 213, 259 (2022). If the party seeking to quiet title establishes possession and legal title, and the opposing party raises the affirmative defense of adverse possession, then the burden shifts to the proponent of the adverse use “to show that it has had the character and is of the duration required by the law.” Dalton v. Real Estate & Improvement Co. of Balt. City, 201 Md. 34, 41 (1952) (citing Cox v. Forrest, 60 Md. 74, 79 (1883)). Because the “use of a way over the lands of another whenever one sees fit, and without asking leave, is an adverse use,” once such adverse use has been established, the responsibility shifts back to “the owner of the land, to show that the use of the way was by license or contract inconsistent with a claim of right.” Clickner v. Magothy River Ass’n Inc., 424 Md. 253, 280-81 (2012) (quoting Cox, 60 Md. at 79-80).

Easements > Creation, Existence, and Termination > Evidence > Presumptions and burden of proof When a non-owner “has used a right of way for twenty years unexplained, it is fair to presume that the use has been under a claim of right, unless it appears to have been by permission.” Garrett v. Gray, 258 Md. 363, 375 (1970) (quoting Smith v. Shiebeck, 180 Md. 412, 419 (1942)). The claim of right requirement “appears ordinarily to be satisfied by acts and circumstances of a character which serve to show that the use[] is adverse; as, for example, by exercising jurisdiction over the road, working it, or expending money in repairing it.” 4 Tiffany Real Prop. § 1214 (3d ed.).

Easements > Creation, Existence, and Termination > Prescription > Adverse Character of Use > Use by permission or agreement “Mere failure to protest is not permission but acquiescence[,]” which is “the inactive status of quiescence or unqualified submission to the hostile claim of another[.]” Dalton, 201 Md. at 50 (quoting Alstad v. Boyer, 228 Minn. 307, 37 N.W.2d 376 (1949)). Easements > Creation, Existence, and Termination > Prescription > Adverse Character of Use > Use by permission or agreement Because Bay City did nothing to assert its own dominion or control over the Intersection, its failure to stop the County from using taxpayer funds to maintain the Intersection was acquiescence; in other words, it was an “unqualified submission to the hostile claim of another, [] not to be confused with permission, which denotes a grant of permission in fact or a license.” Garrett v. Gray, 258 Md. 363, 377-78 (1970).

Eminent Domain > Nature, Extent, and Delegation of Power > Public or Private Use in General > In general The standard for a public easement obviously does not require that one person or group show exclusive use over the twenty-year period. Instead, as the Supreme Court of Maryland has instructed, “[p]ublic use requires that all persons must have an equal right to the use and that it must be in common, upon the same terms, however few the number who avail themselves of it. . . . as it is the right of public travel and not the exercise of the right which constitutes a road a public highway.” Garrett v. Gray, 258 Md. 363, 378 (1970) (quoting Dep’t of Pub. Works & Bldgs. v. Farina, 29 Ill.2d 474, 194 N.E.2d 209 (1963)) (internal citations omitted).

Highways > In General; Establishment > Establishment by Prescription, User, or Recognition > In general Maryland courts have long held that it is possible to establish the existence of a public way by “evidence of an uninterrupted use[] by the public for twenty years” because of “the presumption [] that such long continued use and enjoyment by the public of such way had a legal rather than an illegal origin.” Mt. Sinai Nursing Home, Inc. v. Pleasant Manor Corp., 254 Md. 1, 6 (1969) (quoting Thomas v. Ford, 63 Md. 346, 351-52 (1885)). Such use “serves to give the owner notice” that in order to “dispute the rightfulness of the public use, the owner must assert his or her right within a statutory period by physical action or suit.” 10A McQuillin Mun. Corp. § 30:23 (3d ed.). After such public use for that period, “a perfect title by prescription . . . vests in the public.” Mt. Sinai Nursing Home, Inc., 254 Md. at 5 (citation omitted).

Highways > In General; Establishment > Establishment by Prescription, User, or Recognition > Evidence as to existence of highway Here, the trial court’s finding that the Intersection has been in continuous public use for at least twenty years was fully supported by the testimony of several witnesses that they, and other members of the public, travelled freely through the Intersection without having to request permission, and by the testimony and exhibits demonstrating that the County had improved and maintained the Intersection since 1995. Circuit Court for Queen Anne’s County Case No. C-17-CV-22-000042 REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 0034

September Term, 2023 ______________________________________

BAY CITY PROPERTY OWNERS ASSOCIATION, INC.

v.

COUNTY COMMISSIONERS OF QUEEN ANNE’S COUNTY, ET AL. ______________________________________

Leahy, Albright, Harrell, Glenn T., Jr. (Senior Judge, Specially Assigned),

JJ. ______________________________________

Opinion by Leahy, J. ______________________________________

Filed: October 2, 2024

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2024.10.02 15:07:29 -04'00' Gregory Hilton, Clerk This controversy arises from neighborhood opposition to a planned subdivision in

Queen Anne’s County (the “County”).1 The developer, Land Bridge, LLC, seeks approval

to build ‘Placek’s Place,’ comprising ten homes, on a parcel adjacent to a large existing

residential community known as Bay City. The parcel borders the L-shaped intersection

of Stafford Road and Victoria Drive. Stafford Road is a private road maintained by Bay

City Property Owners Association, Inc. (“Bay City” or “Appellant”), and Victoria Drive is

a public road maintained by the County. The County approved Land Bridge’s plan to

connect the access road to Placek’s Place at the termination of Victoria Road in the L-

shaped intersection.

After learning of the proposed development, Bay City took the position that Stafford

Road subsumes the entire L-shaped intersection, terminating Victoria Drive fifty feet short

of the proposed Placek’s Place development. In February 2022, Bay City brought an action

in the Circuit Court for Queen Anne’s County seeking a declaration that the entire

intersection was part of the private road maintained by Bay City and to quiet title. The

circuit court found in favor of Land Bridge, LLC (“Land Bridge”),2 and the County

(“Appellees” or “defendants” below).

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Bay City Prop. Owners v. Cnty. Comm'rs of Queen Anne's, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bay-city-prop-owners-v-cnty-commrs-of-queen-annes-mdctspecapp-2024.