Chester Jennings, Leonard Barnes and Eunice G. Farrington, Etc. v. Donald Patterson

488 F.2d 436, 1974 U.S. App. LEXIS 10516
CourtCourt of Appeals for the Fifth Circuit
DecidedJanuary 17, 1974
Docket73-1541
StatusPublished
Cited by33 cases

This text of 488 F.2d 436 (Chester Jennings, Leonard Barnes and Eunice G. Farrington, Etc. v. Donald Patterson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chester Jennings, Leonard Barnes and Eunice G. Farrington, Etc. v. Donald Patterson, 488 F.2d 436, 1974 U.S. App. LEXIS 10516 (5th Cir. 1974).

Opinion

RONEY, Circuit Judge:

In this civil rights action plaintiffs allege violation of 42 U.S.C.A. §§ 1981, 1982, 1983, and 1985 in that they were denied access to a public street by a barricade erected by defendants Donald Patterson and Horace Dennis (“the private defendants”), which defendants City of Dadeville, Alabama and its governing officers (“the City”) failed to remove. Plaintiffs seek declaratory and injunctive relief.

At an earlier stage in the proceedings, this Court held that the complaint states cognizable statutory claims. Jennings v. Patterson, 460 F.2d 1021 (5th Cir. 1972). On remand the case was tried to a jury. 1 In response to special interrogatories the jury found that the public had acquired a prescriptive right to use the street, that the private defendants had dedicated the street to public use, that this dedication had been accepted by the City, that the defendants had knowingly deprived the plaintiffs of their right to use thej street, but that this action'was not tak-| en under color of state law. The trial court then granted defendants judgment n. o. v., sua sponte, on the ground that the evidence was insufficient to support the jury findings on prescription and dedication. The Court also noted that the jury determination on state action should have precluded relief. We conclude that the District Court should not have set aside the jury findings of prescription and dedication. In addition, we hold that there was state action within the meaning of Section 1983, an issue of law which should never have been submitted to the jury.

In the early 1940’s, Will Patterson and Fletcher Farrington were adjoining owners of land now within the city limits of Dadeville. Their property was separated by a north-south section line fence. On the Patterson land a road, beginning in the west at Oak Street, extended eastward at least as far as the section line. This road, called Patterson Street, was paved only for about one half of its length, beginning at Oak Street. As portions of the Patterson land were sold off and developed, the paving was extended in segments — to include each new house as it was constructed — until. it reached the driveway *439 of defendant Dennis, owner of the last lot in the tract, approximately 40 feet west of the section line.

In 1969, plaintiff Eunice Farrington (Fletcher’s widow) improved a continuation of the street east of the section line in the course of subdividing a portion of her tract. Thereafter, the City improved and maintained the street system of the newly developed Farrington tract. All lots except the one closest to the section line were sold to blacks. This lot was purchased by James Shaddix, a white.

In 1971, the private defendants constructed a barricade across Patterson Street at the section line, preventing residents of the Farrington tract from using the western portion of the street. Without this access, one and a half to two miles are added to the journey to town. Only James Shaddix, the sole white resident, was offered an easement permitting access to the street.

*440 The defendants, both private and public, contend that the District Judge correctly set aside the jury’s findings on prescription and dedication. Under their view of the evidence, the unpaved strip of the street between the Dennis driveway and the section line remains private property. The private defendants, therefore, claim a right to erect the fence. The City maintains that it is without power to remove the fence from private property.

I.

The defendants filed no motion for judgment n. o. v. In the absence of a timely motion, normally a district court may not grant judgment notwithstanding the verdict. Johnson v. New York, N.H. & H. R.R., 344 U.S. 48, 50, 73 S.Ct. 125, 97 L.Ed. 77 (1952); see F.R.Civ.P. 50(b). In any event, there is ample evidence from which the jury could have found as it did — despite significant evidence supporting defendants’ contentions.

The plaintiffs introduced four Patterson deeds using the intersection of the north side of Patterson Street with the section line as a corner point. A fifth deed also referred to the intersection, and further identified Patterson Street as “also known as Pole Cat Springs Road.” Plaintiffs also introduced testimony that, in the 1940’s, Patterson Street continued eastward from the section line to Polecat Springs, a watering hole located on the Farrington tract that was noted for its mineral waters. This testimony indicated that, at the time, the public traveled the road to reach the Springs and that automobiles had used the road. Although defendants presented evidence that Patterson Street was blocked at the section line by a fence meant to keep cattle on the Farrington side of the line, some witnesses for the plaintiffs testified that there was either a gate or a cattle gap at that point.

The City’s practice of paving the street in sections as new houses were built could have been seen by the jury as the only reason the strip now in question remained unpaved. Similarly, the jury could have discounted the absence of formal dedication of the disputed strip in view of testimony that the City had paved the earlier segments without formal dedication. (The defendants conceded that the paved portions of Patterson Street are public.) Further, the private defendants did not attempt to have the City Council close the street and did not subsequently resort to self-help until a year and a half after the Patterson Street extension on the Far-rington tract had been paved and use of the disputed strip by the new residents of the Farrington tract had begun. The jury could have inferred that this delay stemmed from an earlier intent to dedicate the unpaved portion to public use or from a recognition of the public character of the strip. Evidence that the City maintained the extension and erected a street sign designating the extension as Patterson Street is also consistent with the jury’s findings that the street was public.

Where there is substantial evidence “of such quality and weight that reasonable and fair-minded men in the exercise of impartial judgment might reach different conclusions” a motion for judgment notwithstanding the verdict should be denied. Boeing Co. v. Shipman, 411 F.2d 365, 374 (5th Cir. 1969) (en banc). Accordingly, the jury’s special findings On prescription and dedication must be reinstated.

II.

We next come to the issue of state action under 42 U.S.C.A. § 1983. 2 *441 The Judge charged the jury on “color of state law” in a manner that restricted the jury’s consideration of the question solely to the actions of the private defendants in closing the street. The plaintiffs, however, did not assert state action in the closing of the street. Under their theory, state action was to be found in the City’s failure to remove the barricade.

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Bluebook (online)
488 F.2d 436, 1974 U.S. App. LEXIS 10516, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chester-jennings-leonard-barnes-and-eunice-g-farrington-etc-v-donald-ca5-1974.