Triangle, Inc. v. State

632 P.2d 965, 1981 Alas. LEXIS 531
CourtAlaska Supreme Court
DecidedSeptember 4, 1981
Docket4811
StatusPublished
Cited by22 cases

This text of 632 P.2d 965 (Triangle, Inc. v. State) 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
Triangle, Inc. v. State, 632 P.2d 965, 1981 Alas. LEXIS 531 (Ala. 1981).

Opinions

OPINION

COMPTON, Justice.

This is an appeal from an eminent domain action. The principal issue raised is whether a lessee of real property is entitled to compensation for the state’s elimination of direct access from the property to an abutting highway. Other issues raised on appeal include the proper measure of compensation for a lessee whose property is partially condemned when the lessee holds options to renew its lease, and the proper measure for attorney’s fees, costs and prejudgment interest in eminent domain actions.

As part of a project to widen and upgrade the Steese Highway in Fairbanks, Alaska, the state filed a complaint to condemn .079 acres of land abutting the highway, as well as any and all rights of direct access from the land to the highway. J & B, Inc., owner of the land, had leased its property to Triangle, Inc., appellant in this action.1 In November of 1974, the state filed a Declaration of Taking and deposited $950.00 as just compensation for the land. J & B, Inc. entered into a Stipulation of Settlement with the state and, thus, the trial of this action concerned only Triangle’s interests in the property.

Upon motion for partial summary judgment by the state, the superior court ruled that Triangle was not entitled to any compensation for the elimination of its direct access to the Steese Highway. After a jury trial, the court entered judgment for Triangle in the sum of $1,679.21 as compensation for the taking of the .079 acres.2 Triangle was awarded partial attorney’s fees and costs, as well as pre-judgment interest at the rate of six percent per annum.

On appeal, Triangle seeks to establish its right to compensation for the elimination of its direct access to the Steese Highway. The property it leases from J & B, Ine. is bounded on one side by the Steese Highway and on the other by Farmer’s Loop Road. Before the state’s project, Steese Highway was undivided. A driveway located on the property and used since 1962 provided direct access to both the highway and Farmer’s Loop Road. Farmer’s Loop Road connected with the highway approximately two-tenths of a mile south of the property.

[967]*967After the project was completed, the Steese Highway was a divided, controlled-access highway. Farmer’s Loop Road ended in a cul-de-sac where it had previously intersected the highway. In lieu of that intersection, a connector road between Farmer’s Loop Road and the highway was constructed three-tenths of a mile north of the property. Thus, to travel from the Steese Highway to Triangle’s business, customers must now enter the new connector road, proceed west two-tenths of a mile, turn left onto Famer’s Loop Road and proceed south three-tenths of a mile and then turn into Triangle’s driveway. The net increase in travel distance to the highway is approximately one-half of a mile.

I.

ELIMINATION OF DIRECT ACCESS

The first issue we address is whether the increased and circuitous route from Triangle’s property to the Steese Highway resulting from the state’s project is so unreasonable as to constitute a taking or damaging of Triangle’s property rights for which compensation must be paid.3 All jurisdictions recognize that an owner of abutting land has a right of access to and from a public street or highway.4 In Alaska, this incident of ownership is limited to a “right of reasonable access.” B&G Meats, Inc. v. State, 601 P.2d 252, 254 (Alaska 1979) (emphasis added). This rule is in accord with that adopted by a majority of jurisdictions. Annot., 42 A.L.R.3d 13, 30-48 (1972) (“Abutting Owner’s Right to Damages for Limitation of Access Caused by Conversion of Conventional Road into Limited Access Highway”).

In B&G Meats, we set forth the principles controlling a claim of taking caused- by a change in access to streets or highways:

“No hard and fast rule can be stated, but courts must weigh the relative interests of the public and the individual and strike a just balance so that government will not be unduly restricted in its function for the public safety, while at the same time, give due effect to the policy of eminent domain to insure the individual against an unreasonable loss occasioned by the exercise of the police power. The question depends upon the particular facts of the case. Obviously, if there is a total blocking of access, the restriction would be unreasonable and the abutter entitled to compensation. Where, however, the restriction does not substantially interfere with the abutter’s ingress and egress or where ‘frontage’ or ‘outer roadways’ reasonably provide access the abut-ter is not entitled to compensation. While an abutter has the right of access to the public highway system, it does not follow that he has a direct-access right to the main traveled portion thereof; circuity of travel, so long as it is not unreasonable, is non-compensable. Likewise, loss of business occasioned by the diversion of traffic is non-compensable.”

601 P.2d at 254, quoting Bay v. State Highway Commission, 196 Kan. 13, 410 P.2d 278, 288-89 (1966) (concurring opinion of Fatzer, J.) (citations omitted) (emphasis in original).

The state and Triangle refer us to a multitude of decisions from other jurisdictions,5 but none add to this rule or persuade us that it requires alteration. In accordance with our opinion in B&G Meats, we hold that Triangle never possessed a right of direct access to the Steese Highway; its only right was to reasonable access. Thus, our focus is limited to the narrow issue of whether the superior court erred when it decided that Triangle’s remaining access is, as a matter of law, reasonable.

Triangle urges that the reasonableness of the remaining access is a question of [968]*968fact for the jury and thus the superior court erred in granting summary judgment on the issue. Although there is a jurisdictional split on this issue,6 we have implicitly decided in previous opinions that, it is for the trial court to determine whether the case before it presents a compensable claim for loss of access or merely a claim for traffic diversion, which is non-compensable. See B&G Meats, Inc. v. State, 601 P.2d 252 (Alaska 1979); Alsop v. State, 586 P.2d 1236 (Alaska 1978); Wernberg v. State, 516 P.2d 1191 (Alaska 1973). In the first two of these cases, we affirmed determinations by the superior court that, as a matter of law, the property owners had not presented com-pensable claims for loss of access. B&G Meats, 601 P.2d at 255; Alsop v. State, 586 P.2d at 1240-41. In Wernberg v. State, 516 P.2d at 1201, we decided, as a matter of law, that the owner had stated a valid claim for relief.

It is only when a trial court concludes that the landowner has presented a valid claim that the case is submitted to the jury for a determination of the extent of the taking and the amount of compensation that must be paid by the state. E. g., People v. Becker, 262 Cal.App.2d 634, 69 Cal.Rptr.

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Bluebook (online)
632 P.2d 965, 1981 Alas. LEXIS 531, Counsel Stack Legal Research, https://law.counselstack.com/opinion/triangle-inc-v-state-alaska-1981.