Simms v. Purnell

19 Va. Cir. 138, 1990 Va. Cir. LEXIS 59
CourtSpotsylvania County Circuit Court
DecidedFebruary 26, 1990
DocketCase No. C-88-54
StatusPublished
Cited by1 cases

This text of 19 Va. Cir. 138 (Simms v. Purnell) is published on Counsel Stack Legal Research, covering Spotsylvania County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simms v. Purnell, 19 Va. Cir. 138, 1990 Va. Cir. LEXIS 59 (Va. Super. Ct. 1990).

Opinion

By JUDGE WILLIAM H. LEDBETTER, JR.

In this chancery suit, the plaintiff claims title by adverse possession to a variable-width strip of land, and he claims a prescriptive easement along a gravel road that traverses the defendants’ property. The commissioner in chancery to whom this cause was referred has filed a report rejecting both claims, and the plaintiff has filed exceptions.

Simms owns and resides on a 23.8-acre tract (the "Simms tract") on Route 208 in a rural section of Spotsylvania County. He acquired the property from his mother in 1975. His mother acquired the property from Simms’s father upon the father’s death in 1954. Simms’s father purchased the tract in 1916. Thus, the property has been in Simms’s immediate family for more than seventy years. During his father’s lifetime, the open portions of the tract were farmed and grazed. More recently, some portions have been farmed.

All of the defendants are related to Simms by blood or marriage. They own parcels (collectively, the "Purnell tract") which adjoin the Simms tract on the north. Although they have not lived on their respective parcels as long as the Simms family has lived on the other tract, several of them are familiar with the properties and the history of the uses to which the properties have been put.

[139]*139The northern boundary line of Simms’s tract is essentially a straight line running from Route 208 westerly more than 1,700 feet, as shown by a plat dated November 3, 1986, made by Richard A. Harrison, admitted in evidence on plaintiff’s exhibit # 1. A gravel road lies entirely within the boundaries of the Purnell tract, running parallel to the northern boundary line of the Simms tract. The road leads from Route 208 on the east to the property of others on the west.

Between the gravel road and the northern boundary line of the Simms tract is a variable-width strip, generally thirty feet wide.

The strip of land between the gravel road and Simms’s northern boundary line is the subject of the adverse possession claim. The gravel road is the subject of the prescriptive easement claim.

The commissioner’s recitation of the other pertinent facts (Report, pp. 3-5) is thorough, accurate, and concise and need not be repeated in detail.

Pleadings

Simms instituted this litigation by bill of complaint in February, 1988. The defendants responded. On October 24, 1988, the matter was referred to the commissioner. The commissioner conducted a hearing on December 12, 1988. The testimony given at that hearing is contained in a 169-page transcript, with exhibits attached. The commissioner also conducted a view.

The commissioner filed his report on December 14, 1989. Simms filed exceptions to the report, and arguments on the exceptions were heard by the court on February 20, 1990.

Adverse Possession

Simms claims adverse possession to the center of the gravel road. The commissioner concluded that "the facts do not support a finding of adverse possession to that point." At best, the commissioner reported, Simms established that he possessed "that land lying between the actual boundary line (i.e., the northern boundary line of the Simms tract) and the edge of his regularly [140]*140cultivated field .... The width of [that] strip is not ascertainable with certainty, but the grass has been maintained by a tractor and a bush hog .... Although plaintiff may have possessed a portion of the disputed strip of land, he has failed to prove his ‘intention to claim title to the land itself up to a specific boundary line on the ground.’ Christian v. Bulbeck, 120 Va. 74, 108 (1916)." (Report, pp. 7-8.)

Simms contends that the commissioner misapplied the principles in Christian v. Bulbeck, supra. He argues that he is not required, as the commissioner held, to prove that he intended to claim ownership of land which he knew was not his. Instead, he says, he is required to prove open, notorious, exclusive, and continuous possession for the statutory period, and he has done that by evidence of grazing and cultivation within the strip between 1916 and 1954, at which time such adverse use ripened into legal title.

Christian v. Bulbeck is a "mistaken boundary line" case. The author of this opinion has had occasion to analyze that case in another adverse possession dispute. See Fortune v. Rich, 13 Va. Cir. 59 (1987) (opinion dated December 2, 1987, pp. 4-7). Christian v. Bulbeck stands for the proposition that occupancy to a visible and ascertained boundary for the statutory period is the controlling factor in determining the element of "hostility" in such cases. The fact that the occupancy may have been under mistake or ignorance as to boundary lines is immaterial. A national publication cites Christian v. Bulbeck for the proposition that where an intention is manifested to claim title to a visible, fixed, and ascertained boundary line, the possession is hostile, although it is erroneously assumed to be the true line and possession is held and the claim is made because of the mistake as to the location of the boundary. See 3 Am. Jur. 2d, Adverse Possession § 60.

Simms misconstrues the purpose for which the commissioner cited Christian v. Bulbeck. The commissioner’s report does not suggest that Simms’s claim turns on the element of "hostility." Instead, he accurately cited the case for the proposition that an adverse possession claimant must show some intent, whether derived from mistake or an erroneous assumption or whatever, to occupy and claim title to some fixed, ascertainable point or location on [141]*141the ground. It is the commissioner’s view, as the court interprets the report, that Simms failed to establish these rudimentary prerequisites.

A commissioner’s report is not entitled to the same weight as a jury verdict. Virginia Code § 8.01-610. However, it is entitled to great respect; and where, as here, the evidence has been taken in the commissioner’s presence, his findings of fact are presumptively correct and should not be arbitrarily disturbed. Hill v. Hill, 227 Va. 569 (1984).

Upon an independent review of all the evidence and the applicable legal principles, the court agrees with the commissioner.

Although Simms and his predecessors used the strip or portions of it for grazing and, at other times, for cultivation, the evidence is not sufficient to enable the court to determine with any particularity the location of the line to which Simms and his predecessors have claimed. Clearly, the evidence does not support Simms’s claim to the center of the gravel road.

At some time, there was a fence. The fence ran basically parallel to the gravel road, about three-to-eight feet to the south of the road. Several cedar trees now stand where a stretch of the fence apparently was located. Simms’s evidence indicates that the fence was erected by his father when he was grazing livestock on a portion of the Simms tract.

How does the existence of an old fence line located three to eight feet off the road prove title by adverse possession to the center of the road? When asked this precise question at the February 20th hearing, counsel for Simms responded that a landowner cannot run a fence down the center of a road. This explanation, a nonsequitur, adds no strength to Simms’s claim to the center of the road.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lloyd v. Purnell
61 Va. Cir. 463 (Virginia Circuit Court, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
19 Va. Cir. 138, 1990 Va. Cir. LEXIS 59, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simms-v-purnell-vaccspotsylvani-1990.