Patricia Bush v. Fayette County, Texas

CourtCourt of Appeals of Texas
DecidedApril 13, 2006
Docket03-05-00274-CV
StatusPublished

This text of Patricia Bush v. Fayette County, Texas (Patricia Bush v. Fayette County, Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patricia Bush v. Fayette County, Texas, (Tex. Ct. App. 2006).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-05-00274-CV



Patricia Bush, Appellant



v.



Fayette County, Texas, Appellee



FROM THE DISTRICT COURT OF FAYETTE COUNTY, 155TH JUDICIAL DISTRICT

NO. 2001V-215, HONORABLE HENRY J. STRAUSS, JUDGE PRESIDING



M E M O R A N D U M O P I N I O N



In this suit between a landowner and a county regarding the characterization of a section of road in the county as public or private, appellant Patricia Bush contends that the district court erred by granting summary judgment in favor of appellee Fayette County and determining that the road was public. For the reasons set forth below, we affirm the district court's judgment granting summary judgment in favor of the County.



FACTUAL AND PROCEDURAL BACKGROUND



At issue is an approximately .6 mile portion of St. James Church Road in Fayette County that begins at its intersection with Old Lockhart Road and extends southward until it ends at a cattle guard. The road has been in existence at least since 1937. It appeared on a 1965 highway map prepared by the State Department of Highways and Public Transportation, and on the county's 1972 and 1987 compilations of its roads. The .6 mile portion at issue was omitted from a 1991 compilation.

Use of the road by the public dates back to at least 1937. In addition, since at least the 1970s, the County has maintained the .6 mile portion by blading the gravel road and trimming brush and trees from the fences running along both sides of the road.

In early 2002, a newly constructed locked gate appeared on St. James Church Road just south of its intersection with Old Lockhart Road, blocking access to the .6 mile section at issue. Subsequently, the County filed suit seeking a declaration that the road is a public road, and an injunction ordering Bush and her husband, Irvin Davis, to remove the obstruction. (1)

Both the County and Bush filed motions for summary judgment. In its motion, the County contended that the .6 mile portion became a public road through an implied dedication, or, alternatively, through prescription, and that the County had adduced proof entitling it to a judgment as a matter of law based on both theories. Bush contended that as a matter of law the County was unable to prove elements required for it to prevail on either of its theories. The district court granted the County's motion for summary judgment and denied all relief to Bush.



ANALYSIS



In this appeal, we must address whether the trial court erred in granting the County's summary judgment. The County relied on two theories in its motion for summary judgment: (1) implied dedication to public use, and (2) easement by prescription. Because our determination regarding implied dedication is dispositive, we need not reach the prescriptive easement issue.

We review summary judgments de novo. Valence Operating Co. v. Dorsett, 164 S.W.3d 656, 661 (Tex. 2005). A movant has the burden of showing that there is no genuine issue as to any material fact and that it is entitled to a judgment as a matter of law. Tex. R. Civ. P. 166a(c); Nixon v. Mr. Prop. Mgmt. Co., 690 S.W.2d 546, 548 (Tex. 1985). The nonmovant has no burden to respond to a summary judgment motion unless the movant conclusively establishes its cause of action or defense. Rhone-Poulenc, Inc. v. Steel, 997 S.W.2d 217, 222-23 (Tex. 1999). When reviewing a motion for summary judgment filed pursuant to rule 166a(c), we take the nonmovant's evidence as true, indulge every reasonable inference in favor of the nonmovant, and resolve all doubts in favor of the nonmovant. See Nixon, 690 S.W.2d at 548-49.

Common-law dedications may be express or implied. Implied dedications, such as the one at issue here, are based on the unequivocal acts and conduct of the landowner. See O'Connor v. Gragg, 339 S.W.2d 878, 882 (Tex. 1960). The parties agree that this dispute implicates chapter 281 of the transportation code, which abolished the common law doctrine of implied dedication in counties with populations of less than 50,000. See Tex. Transp. Code Ann. § 281.003(b) (West 1999) ("An oral dedication or intent to dedicate by overt act is not sufficient to establish a public interest in a private road under this chapter."). The statute, however, does not apply retroactively and, therefore, does not affect an implied dedication occurring before its effective date of August 31, 1981. Lindner v. Hill, 691 S.W.2d 590, 592 (Tex. 1985); Las Vegas Pecan & Cattle Co. v. Zavala County, 682 S.W.2d 254, 256 (Tex. 1984). Thus, in determining whether an implied dedication occurred, we look only to actions occurring prior to August 31, 1981.

The elements of implied dedication are: (1) the acts of the landowner induced the belief that the landowner intended to dedicate the road to public use; (2) he was competent to do so; (3) the public relied on these acts and will be served by the dedication; and (4) there was an offer and acceptance of the dedication. Lindner, 691 S.W.2d at 592; Zavala County, 682 S.W.2d at 256. We will discuss each of these elements.

Bush asserts that the County's summary judgment evidence failed to prove as a matter of law that the acts of the landowner induced the belief that the landowner intended to dedicate the road to public use. Generally, in order to meet this element, a party must show a "clear, unequivocal act or declaration by the owner of his intention to set the roadway apart for the public use." O'Connor, 339 S.W.2d at 882; Oswald v. Grenet, 22 Tex. 94, 99 (1858). However, an important corollary to this rule is that when the origin of the use by the public, and the ownership of the land at that time, are "shrouded in obscurity," and no proof can be adduced to show the intention of the owner in allowing the use, the law raises a presumption that the requisite intention and acts disclosing it were present. O'Connor, 339 S.W.2d at 882; Dunn v. Deussen, 268 S.W.2d 266, 269 (Tex. Civ. App.--Fort Worth 1954, writ ref'd n.r.e.). As this Court has previously stated, this corollary is designed to meet a particular anomaly--evidence of long-continued use by the public. Barstow v. State

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Valence Operating Co. v. Dorsett
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Rhone-Poulenc, Inc. v. Steel
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O'CONNOR v. Gragg
339 S.W.2d 878 (Texas Supreme Court, 1960)
GMC v. Saenz on Behalf of Saenz
873 S.W.2d 353 (Texas Supreme Court, 1994)
Dunn v. Deussen
268 S.W.2d 266 (Court of Appeals of Texas, 1954)
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Oswald v. Grenet
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Patricia Bush v. Fayette County, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patricia-bush-v-fayette-county-texas-texapp-2006.