Thompson v. City of Columbus

22 Ohio N.P. (n.s.) 33, 30 Ohio Dec. 196, 1919 Ohio Misc. LEXIS 35
CourtCourt of Common Pleas of Ohio, Franklin County, Civil Division
DecidedApril 4, 1919
StatusPublished
Cited by2 cases

This text of 22 Ohio N.P. (n.s.) 33 (Thompson v. City of Columbus) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. City of Columbus, 22 Ohio N.P. (n.s.) 33, 30 Ohio Dec. 196, 1919 Ohio Misc. LEXIS 35 (Ohio Super. Ct. 1919).

Opinion

Rathmell, J.

The plaintiff sues to recover the possession of certain real estate alleged to belong to him, being two narrow strips of land lying east of Summit street originally embraced within Indianola Summit Addition. The defendant denies generally the claims of plaintiff.

It appears that on June 16, 1892, the plaintiff together with nine other persons, lessees under a ninety-nine year lease, and the lessor, all representing the entire interest in the real estate platted 133.182 acres just outside the limits of the city in [34]*34Clinton township, Franklin county. The plat showed the land divided into several hundred lots bordering on streets and alleys, and the two spaces within Indianola avenue, in controversy here, marked “park.” The plat was acknowledged before a notary public, by the makers, as a true representation of their subdivision, was certified as correct by deputy county surveyor, was approved by the county commissioners, and was filed for record and recorded in plat book 5, p. 140, by the county recorder on. June 27, 1892.

The certification stated that the streets and alleys as set forth on' said pla,t are hereby dedicated to the public use as highways. Lots were sold with reference to the plat and all have been sold.

It is contended by defendant that this constituted a statutory dedication to the public use of the two spaces each marked “park.”

The plaintiff contends that the owners having designated the streets and alleys as dedicated to the public use, the spaces marked “park” were excluded. All statutory requirements, it appears, were conformed to in the matter of platting a subdivision or addition to a municipal corporation. And by force of the statute, G. C. 3589, such a plat or map vested fee simple of all such parcels of land as were therein expressed, named, or intended for public use in the county for the uses and purposes therein named, expressed or intended. This addition was subsequently annexed or incorporated or taken into the city and there is no contention, that any title or right acquired by the countjr did not inure to the city. No omissions of the formalities for a'statutory dedication are pointed out by diligent counsel. in the matter .of platting the land. But counsel for plaintiff contends that the spaces marked “park”'not having been named in the certification of the owners were excluded and not dedicated.

It would appear that the mere failure to designate that the “parks” were thereby dedicated to public use is not conclusive of failure to dedicate, if it should appear that it was the intention of the owners to dedicate them.

[35]*35Suppose in view of the statute G-. C. 3585, affecting municipalities, the owners had specifically named and designated that the parks so marked were thereby dedicated to the public use, and had made no mention of the streets and alleys, shown on said map as apparently intended for such, would it be contended in the absence of language to the contrary that the streets and alleys so shown would not be dedicated? If hot, then the converse would follow. The language of the statute is that such a plat or map shall be deemed in law a sufficient conveyance to vest the fee simple of all such parcels of land as are therein expressed, named or intended for public use, for the uses and purposes therein named, expressed or intended. So if it can be found that the owners intended the spaces marked “park” for public use, the dedication would follow.

“When the owner of real property lays out a town upon it and divides the land into lots and blocks intersected by streets and alleys and sells any of the lots with reference to such plan; or when he sells with reference to the map of a town or city in which his land is so laid off, he thereby dedicates the streets and alleys to the use of the public, unless it appears either by express statement in the conveyance or otherwise that the mention of the street was solely for purposes of description and not as a dedication thereof. On the same principle the owner .will be held to have dedicated to the public use such pieces of land as are marked on the plat or map as squares, courts or parks.” 13 Cyc., 455.

Doctrine of dedication to public uses is extended and applied to parks and public squares; and the fact of dedication may be established in the same manner as in case of streets. Morrow v. Highland Grove Traction Co., 219 Pa., 619, 624. An intent on the part of the owner to dedicate is essential and such intention can be found in the facts and circumstances of the particular case, manifested by the acts of the land owner.

“Where a plat is made and recorded and lots sold with reference thereto, the requisite intention is generally indisputable. ’ ’ Dillon on Mun. Cor., Section 10795.

[36]*36“The word ‘park’ written upon a block upon a map of city property indicates a public use; and conveyances made by the owner of the platted land by reference to such map operate conclusively as a dedication of the block.” Price v. Plainfield, 40 N. J. L., 608; Maywood Co. v. Village of Maywood, 118 Ill. 61.

“Where there has been laid out and filed a plat of land as an addition to a city upon which plat a portion of the land is designated as a ‘park’ and there has been a sale of lots in reference to the plat, the dedication of the ‘park’ thus effected is to the public.”

“An irrevocable dedication of land is effected by designating certain land on a map filed in the county recorder’s office as a ‘park’ and selling lots with reference to the map.” Rhode v. Town of Brightwood, 145 Ind., 21.

In Archer v. Salinas City, 93 Cal., 43, it is held:

“The word ‘park’ written upon a block of land designated upon a map of property within the limits of an incorporation city or town, signifies an open space intended for the recreation and enjoyment of the public, and this signification is the same whether the word be used alone or with some qualifying term as ‘Central Park.’ And- in the opinion the court says: ‘The word “park” written upon a block of land designated upon a map is as significant of a dedication and of its use to which the land is dedicated as is the word “street” written upon such map.’ ” See also Steel v. Portland, 23 Oregon, 176; Commonwealth v. Hazen, 207 Pa., 52, 56; Dillon on Municipal Corporations, 5th Ed., 1096.

In Erik v. Ramstad, 31 N. D., 504, reported in L. R. A. 1916 B., 1160, is a well considered and analogous case. There a tract marked “Lincoln Park” was involved in a plat of land indorsed on which was that the owner had caused the same to be platted and hereby donates and dedicates to the public use all the streets and alleys thereon shown. Just as in this case there was no express mention of the “park” and just as in this case lots were, sold with reference to the plat. In that ease it was held: (1) There can be no dedication in the absence of an [37]*37intent on the part of the owner to dedicate. (2) Such intent, however, is to be ascertained from the acts of the owner and not from the purpose hidden in his mind. (3) When the owner plats his property and sells lots with reference to the plat, he thereby manifests an indisputable intention to dedicate the public places shown on such plat.

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Bluebook (online)
22 Ohio N.P. (n.s.) 33, 30 Ohio Dec. 196, 1919 Ohio Misc. LEXIS 35, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-city-of-columbus-ohctcomplfrankl-1919.