Laughlin v. Everhart

678 P.2d 926, 1984 Alas. LEXIS 263
CourtAlaska Supreme Court
DecidedFebruary 10, 1984
DocketNos. 7360, 7453
StatusPublished
Cited by3 cases

This text of 678 P.2d 926 (Laughlin v. Everhart) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laughlin v. Everhart, 678 P.2d 926, 1984 Alas. LEXIS 263 (Ala. 1984).

Opinion

OPINION

MATTHEWS, Justice.

In this case appellant Laughlin .contends that a road, called by the parties Tribulation Trail, is public or, alternatively, that he has acquired an easement to it. Laughlin is the owner of 141.16 acres of land located near Rosie Creek Road, a public highway in the Fairbanks North Star Borough. Laughlin purchased this property in 1965 from a third party. When Laughlin bought his land it was separated from Rosie Creek Road by two parcels. The parcel nearest Rosie Creek Road does not concern this case as the parties have, for the purposes of this case, treated that part of Tribulation Trail which crosses this property as a public road. The other parcel was a homestead entry in the name of John Teas. Teas acquired patent to his homestead in 1968.

In 1965 Tribulation Trail ran from Rosie Creek Road to Teas’ homesite, but not to Laughlin’s property.1 Teas also had access from his homesite to Rosie Creek Road by means of another road, referred to by the parties as the lower road. Laughlin and Teas allege that this alternate access road is impassable much of the time. In 1971 Teas deeded the eastern half of his homestead to Skelton and reserved access across the lower road. Later in 1971 and 1972 Teas sold 10 acre parcels to Demoski, Ever-hart, Schoen, and Presnell. In 1975 Teas sold a 35 acre parcel to New and his home-site parcel to Quist. Tribulation Trail crossed all these parcels, except Skelton’s. In 1976 Demoski subdivided his land into four equal parcels. That same year Douglas Everhart and his wife Jeannie divided their property into four equal pieces of property, two owned by Jeannie and two owned by Douglas. Neither Teas, nor De-moski, nor the Everharts recorded an approved subdivision plat prior to the conveyances which they made. In 1979 Laughlin, by agreement with New, built a road connecting Laughlin’s property with Tribulation Trail.

[928]*928[[Image here]]

In 1981 Laughlin sued Demoski and Ev-erhart. He sought, among other things, a declaration that Tribulation Trail was a public road, or alternatively, a declaration of an easement along Tribulation Trail as it crossed defendants’ property. Laughlin moved for summary judgment. The defendants opposed the motion and suggested that, if anything, they were entitled to summary judgment. The court agreed, and on July 2, 1982 published a memorandum decision granting summary judgment to defendants.2 Laughlin sought reconsideration based on a theory, among others, that since Demoski and Everhart had subdivided their property without complying with applicable subdivision requirements, [929]*929they should be estopped to deny that Tribulation Trail as it crossed their property was public. Laughlin argued that if they had complied with the subdivision requirements they would have been forced to dedicate that portion of Tribulation Trail which crossed their property as a public road. The court accepted this theory as to Demo-ski but not as to Everhart. Judgment was entered in favor of Laughlin against Demo-ski, and in favor of Everhart against Laughlin. Both losing parties have appealed.

I.

Laughlin’s primary point on appeal is that the trial court should have used the same theory it used as to Demoski’s act of illegal subdivision with respect to the illegal transfers made by Teas. AS 40.15.-0103 and Fairbanks North Star Borough Code of Ordinances (hereafter FNSB) § 17.04.0304 require submission, approval, and recording of a plat before a property owner can divide and sell his property or any portion thereof. FNSB § 17.16.0405 sets forth certain requirements for approv[930]*930al, including the provision of access roads. AS 40.15.0306 provides that all platted roads are deemed to have been dedicated to the public.

Both the state statutes and the local ordinances prescribe remedies for violation. AS 29.33.1907 makes noncompliance a misdemeanor punishable by up to a $500 fine for each lot sold. The platting authority is also given power to enjoin transfers. FNSB § 17.36.0108 allows anyone to file a complaint with the planning officer, who must investigate and take appropriate action within thirty days. FNSB § 17.36.-0209 also provides for a $500 penalty for each lot transferred and permits the Borough to obtain an injunction preventing a transfer.

Laughlin bases his argument primarily on the equitable maxim that “equity requires to be done that which should have been done.” With respect to the subdivision of Teas’ property, we do not believe that the remedy advocated by Laughlin is appropriate.

First, it is speculative as to what access would have been required if Teas had submitted a plat for approval to the platting authority. It is possible, for example, that dedicated access in a location different than the roadway occupied by Tribulation Trail would have been required.

Second, the remedy of enforced dedication of Tribulation Trail, or any other access, goes well beyond the remedies provided which are, as previously noted, a maximum fine of $500 for each sale and injunction of each sale. In Price v. S.S. Fuller, Inc., 639 P.2d 1003, 1004-1005 (Alaska [931]*9311982) we noted the existence of these two remedies and declined the invitation to hold that a third remedy, that of unenforceability of a transfer of unplatted land, should be implied. We take a similar approach here. Decreeing that Tribulation Trail should be considered a dedicated road because Teas had not complied with applicable subdivision requirements would be tantamount to taking property from Teas’ transferees. While such a taking would not necessarily be unconstitutional,10 such a remedy differs so substantially from those which are statutorily provided as to preclude judicial implication.11

With respect to the subdivision of Demo-ski’s property, it is by no means clear that the platting authority would have required that Tribulation Trail as it crosses Demo-ski’s property be dedicated as a public road, since doing so would not provide access to all four parcels created in Demoski’s subdivision. Indeed, the record indicates that the Borough was aware of Demoski’s subdivision and declined to take action because it believed that sufficient access to the lots was provided.12 Thus the remedy imposed by the trial court is not necessarily similar to what would have taken place had Demo-ski complied with the subdivision requirements. Further, the remedy differs significantly from that which is statutorily prescribed. We conclude, therefore, that the court erred in holding that Tribulation Trail should be considered as a public road where it crosses Demoski’s land because of Demoski’s failure to comply with the subdivision requirements.

Appellant’s argument as to Everhart is the same as that which pertains to Demo-ski. The trial court found, however, that the Everhart parcel should be treated differently because the Everhart land was not subdivided for the purpose of sale, a requirement of AS 29.78.010(16). We need not consider whether this conclusion was correct.

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678 P.2d 926, 1984 Alas. LEXIS 263, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laughlin-v-everhart-alaska-1984.