2009-02-19
.
f
GERALD A. VERGILlS.
KENNETH M. STENGER
ALBERT P. ROBERTS
THOMAS R. DAVIS
JOAN F. GARRETT"
VERGILIS, STENGER, ROBERTS & DAVIS, LLP
A TTORNEYS AND COUNSELORS AT LAW
I 136 ROUTE 9
WAPPINGERS FALLS, NEW YORK 12590
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KAREN MacNISH
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KEVIN T. McDERMOTT
ANGEL I. FALCON
ANTHONY M. DEFAZIO".
JAMES P. HORAN".
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February 19, 2009
Gellert & Klein, P.e.
75 Washington Street
Poughkeepsie, New York 12601
Attention: Stephen E. Diamond, Esq.
RECEIVED
FEB 2 0 2009
Re: Adams Fairacre Farms Project
VSRD File No. 12949.0495
Dear Steve:
TO\N'" CLERK
Enclosed please find letter forwarded to Rich Peters as per last Friday's meeting. At this
point I believe I have to turn the matter over to you and hopefully Senator Saland to
obtain the appropriate consent from NYS DOT.
I attended the Association of Towns convention in New York City on Monday and
Tuesday. One of the presentations was Rights of Way Management Issues presented by
the The Ayers Law Firm, PLLC, 50 West Grand Street, P.O. Box 683, Palatine Bridge,
New York 13428, www.theayerslawfirm.com. I spoke to Ken Ayers after his presentation
and discussed the Adams/Route 9 abandonment issue. He indicated that the leading case
was the Frankfater case, 17 A.D.2d 515, 235 N Y.S.2d 476. He also indicated that these
issues were discussed in the book that he published "Surveyor's Handbook - New York
State Highway Law". Quite frankly, Mr. Ayers was exceptionally knowledgeable in this
area of law and we might look to him for some guidance. In any event, I do not know that
I can do anything more to resolve the title issues. This is certainly an area of law that is
esoteric to say the least.
-I
,
Page 2
Please advise thoughts.
Very truly yours,
V~:IlTENGER, ROBERTS & DA VIS, LLP
ALBERT P. ROBERTS
APR/so
Enclosure
cc: Town Board
Graham Foster, Highway Superintendent
Herbert Jacobson, Esq.
Rights of Way Management Issues
Determining the Width of Town Highways Created by Prescription
And
Effective Discontinuance and Abandonment of Town Highways)
Presented By
Kenneth L. Ayers, Esq. and Laura E. Ayers, Esq.
The Ayers Law Firm, PLLC
50 West Grand Street, P.O. Box 683
Palatine Bridge, New York 13428
www.theaYerslawfirm.com
Width of Town Highways Created by Prescription
I. Generally
The width of any given highway is generally a function of how that particular
highway was established. Thus, in determining the width of a given highway the first
inquiry must be: How was this particular highway established?
2. Creation of Town HilZhways by Prescription
Prescription is a method of acquiring rights in the lands of another, such as an
easement for highway purposes, by adverse use. In order for an easement to arise by
prescription, the user must be open and notorious, continuous, uninterrupted, undisputed
and adverse to the title holder of the land.2 A highway established by prescription gives
the public only an easement for highway purposes, rather than a fee simple interest and,
therefore, title in the roadbed remains in the owner of the adjoining land.3
I Materials presented here are excerpted from "Surveyor's Handbook-New York State Highway Law"
Copyright 2008 by Kenneth L. Ayers, Esq, The Ayers Law Finn, PLLC, P.O. Box 683, 50 West Grand
Street, Palatine Bridge, NY 13428 and are reproduced here with the permission of the author. Copies of the
complete Surveyor's Handbook are available at www.theaverslawfmn.com
2 2 CJS Adverse Possession ~ 3 (1972).
3Heyert v. Orange and Rockland Utilities, Inc., 17 NY 2d 352 (l966).
\I'je'c.tl,:~\(' !
\ ," _ _-' L '.--' \- ..
17 A.D.2d 515
17 A.D.2d 515, 235 N.Y.S.2d 476
(Cite as: 17 A.D.2d 515, 235 N.Y.S.2d 476)
Page 1
(>
Supreme Court, Appellate Division, Third Department, New York.
Julius FRANKF A TER, Jacob Frankfater and Julius Frank, Claimants-Respondents
v.
The STATE of New York, Appellant.
Claim No. 36184.
Dec. 28, 1962.
Proceeding on claim against state for appropriation of land to widen highway. The Court of
Claims, Alexander Del Giorno, 1., 32 Misc.2d 130, 225 N.Y.S.2d 78, entered money judgment
for claimants, and state appealed. The Supreme Court, Appellate Division, Reynolds, J., held that
evidence established that state had the title to land involved on ground that old turnpike, under
which state derived title to road, followed same course as did road at time of trial, and that new
trial would be granted in interests of justice to allow claimants to produce further evidence bear-
ing on issue of state's title where claimants had entered trial without notice that state was claim-
ing title to land in question.
Judgment reversed, and new trial granted.
West Headnotes
[1] Highways 200 ~68
200 Highways
2001 Establishment
2001(8) Establishment by Statute or Statutory Proceedings
200k68 k. Pleading and Evidence as to Existence of Highway. Most Cited Cases
Evidence established that original taking, which was for turnpike, and under which state subse-
quently derived title, was for a road six rods in width.
[2] Turnpikes and Toll Roads 391 (::=>25
391 Turnpikes and Toll Roads
3911 Establishment, Construction, and Maintenance
391 k25 k. Acquisition of Road by Public Authorities. Most Cited Cases
Evidence established that title to land abandoned by turnpike company passed to state pursuant
to 1838 statute providing that, whenever turnpike corporation was dissolved or road discontin-
ued, road was to become a public highway. Laws 1838, c. 262; Laws 1801, c. 36.
@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
17 A.D.2d 515
17 A.D.2d 515, 235 N.Y.S.2d476
(Cite as: 17 A.D.2d 515, 235 N.Y.S.2d 476)
Page 2
[3J Highways 200 €=>47
200 Highways
2001 Establishment
200l(B) Establishment by Statute or Statutory Proceedings
200k47 k. Width of Road. Most Cited Cases
Proof of actual use will be determinative of extent of taking whenever statute prescribes maxi-
mum and minimum width of highway.
[4J Adverse Possession 20 C=>8(2)
20 Adverse Possession
201 Nature and Requisites
201(A) Acquisition of Rights by Prescription in General
20k5 Property Subject to Prescription
20k8 Property Dedicated to or Acquired for Public Use
20k8(2) k. Highways and Turnpikes. Most Cited Cases
Establishment of prescribed 40-year period and other elements necessary for adverse possession
would not cause title to land taken for road purposes to ripen in adjoining landowners, since ef-
fect would be inconsistent with public right to passage over public highway.
[5J Eminent Domain 148 €;:;:J300
148 Eminent Domain
148IV Remedies of Owners of Property; Inverse Condemnation
148k294 Evidence
148k300 k. Weight and Sufficiency. Most Cited Cases
In proceeding on claim against state for appropriation of land to widen highway, evidence estab-
lished that state had title to land involved on ground that old turnpike, under which state derived
title to road, followed same course as did road at time of trial. Highway Law, S 30; Laws 1801, c.
36; Laws 1838, ch. 262.
[6J States 360 ~184.40(5)
360 States
360V Claims Against State
360k184.40 Scope and Extent of Review
360kI84.40(5) k. Determination and Disposition of Cause. Most Cited Cases
(Formerly 360kI84.44)
New trial would be granted in interests of justice, in proceeding on claim against state for appro-
priation of land to widen highway, to allow claimants to produce further evidence bearing on is-
sue of state's title where claimants had entered trial without notice that state was claiming title to
(Q 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
17A.D.2d515
17 A.D.2d 515, 235 N.Y.S.2d 476
(Cite as: 17 A.D.2d 515, 235 N.Y.S.2d 476)
Page 3
land in question.
**477 *516 Louis 1. Lefkowitz, Atty. Gen., of the State of New York (Paxton Blair, Sol. Gen.,
Jean M. Coon, Asst. Atty. Gen., Albany, of counsel), for appellant.
Rosen & Rosen, Monticello (George H. Rosen, Monticello, of counsel), for respondents.
Before *518 BERGAN, P. 1., and COON, GIBSON, REYNOLDS and TAYLOR, 11.
REYNOLDS, Justice.
[1][2][3][4] Involved here is a five foot wide strip in Sullivan County which the State proposes to
utilize to widen Route 17B. The property in question was retained by respondents from a larger
piece of property **478 they are in the process of subdividing for development. While the deed
recites as the purpose of the reservation to lay water lines, in fact the water lines have been laid
to the rear of the property and respondents now claim the real reason for the reservation was so
that a wall could be erected between Route 17B and the development to prevent commercial use
of property abutting the road. The State contends that it owns the property in question, tracing its
title to the Newburgh and Cochecton Turnpike Company chartered in 1801 (L.1801, C. 36). It
maintains that the center line of Route 17B is the center line of the old turnpike; that the original
taking for the turnpike was six rods in width and that, therefore, respondents have no title to the
property in dispute. It is our opinion that the State derived title to the turnpike as constituted un-
der the 1801 charter and that the original taking was for a road six rods *517 in width. On the
question of the State's acquisition of title the legislative enactment of 1838 (L.1838, C. 262) pro-
viding that whenever a turnpike corporation was dissolved or the road discontinued the road was
to become a public highway is dispositive. The record indicates that the Newburgh and Cochec-
ton Company abandoned the property no earlier than 1865. At this point title passed to the State
pursuant to the 1838 enactment. Additionally, there is no proof that the road was not continu-
ously in operation under legislative aegis from its inception through 19 I 1 when the State as-
sumed control of the road as a State highway (City of Cohoes v. D. & H. Canal Co., 134 N.Y.
397, 31 N.E. 887), and in fact the opposite would actually appear to be the case. As to the width
of the taking involved, it is undisputed that the 1801 legislation establishing the turnpike author-
ized a maximum taking of up to six rods in width and a minimum of four rods. While the general
rule is that whenever a statute prescribes the maximum and minimum widths proof of actual use
will be determinative of the extent of the taking (25 Am.Jur. 'Highways', ~ 36. p. 360; Anno. 76
A.L.R.2d 535, 'Highways-Width and Boundaries', ~ 11, p. 557), a review of the evidence here,
especially the reports of the Commissioners of Appraisal, indicates that a six rod width was ap-
propriated and paid for. It is undisputed that if the original taking was but the minimal four rods
prescribed by the statute, it would include the strip in controversy. Respondents assert that since
only three rods were actually utilized, the 1911 State take over contract plans indicate only a
three rod road, the taking map filed pursuant to ~ 30 of the Highway Law indicated respondents
owned the property involved and the State paid other people on the basis of the taking map, the
State is estopped from asserting title to more than a three rod width. Even assuming that respon-
dents can establish that they have suffered a legal detriment as a result of the State's action upon
which estoppel would lie (compare 6 New York Jurisprudence, 'Boundaries', ~ 61 et seq. and ~
@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
17 A.D.2d 515
17 A.D.2d 515, 235 N.Y.S.2d 476
(Cite as: 17 A.D.2d 515, 235 N.Y.S.2d 476)
Page 4
75 et seq.) we find no authority that would sanction the use of the theory of estoppel to deprive
the sovereign of land conferred to it by statute.**479 Nor even if the prescribed 40 year period
and the other elements necessary for adverse possession were established would title ripen here
since the effect would be inconsistent with the public right to passage over a public highway
(Beisham v. People, 26 Misc.2d 684,690,39 N.Y.S.2d 333).
[5] The most vexing aspect of this case is whether the evidence advanced by the State is ade-
quate to prove that the old turnpike laid out under the statute of 1801 follows the same course as
does the present 17B. If this is established it is clear that the State must prevail (Schillawski v.
State, 9 N.Y.2d 235, 213 N.Y.S.2d 68, 173 N.E.2d 793). In Schillawski the Court of Appeals
dispelled all arguments that use rather than the statute determines the width and that failure to
improve the entire width taken constitutes an abandonment of the unimproved portion. To estab-
lish its position the State first produced a survey made in 1806 which established the center line
of the turnpike along what is new respondents' land. Next the State introduced a witness who
plotted that old survey to the same scale as was used in the 1911 contract plans and also to the
scale in the 1955 contract plans connected to the present taking. When overlays of the 1806 sur-
vey as replotted were placed on the 1911 and 1955 maps the center line of the road was almost
exactly the same. The court below, despite this evidence, found that the State had not dispelled
the possibility that the road might have been relocated due to inconsistencies in the testimony of
the State's witnesses. While admittedly testimony by the State's own witnesses indicating that
using the description in certain deeds the center line would be other than as presently constituted
is some evidence to substantiate respondents' contention of the possibility of a center line devia-
tion, we do not find these discrepancies sufficient to warrant a disregard of the vivid evidence
portrayed by the overlays especially since the preparation of the overlays was not dependent on
these descriptions. Respondents' argument that the State did not prove that the strip in question
abutted the old turnpike must fall on the same evidence, for if the present Route 17B abuts the
strip and 17B follows the route of the old turnpike then the old turnpike must also have abutted
the same land. On the basis of the present record we find that the State has established title to the
property here involved.
[6] Since claimants, however, entered this trial without notice that the State claimed title to the
strip in question, in the interests of justice a new trial should be granted to allow claimants to
produce any further evidence bearing on the issue.
The judgment should be reversed and a new trial granted, without costs.
Judgment reversed, on the law and the facts, and a new trial granted, without costs.
BERGAN, P. 1., and COON, GIBSON and TAYLOR, 11., concur.
N.Y.A.D. 1962
Frankfater v. State
17 A.D.2d 515, 235 N.Y.S.2d 476
@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
17 A.D.2d 515
17 A.D.2d 515, 235 N.Y.S.2d 476
(Cite as: 17 A.D.2d 515, 235 N.Y.S.2d 476)
END OF DOCUMENT
(Q 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
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