City of Kentwood v. Sommerdyke Estate

Taylor, J.

(concurring in part and dissenting in part). I agree with the majority that a highway created by user pursuant to MCL 221.20; MSA 9.21 is presumptively four-rods (sixty-six feet) wide. However, I disagree with the majority’s analysis of the issue in terms of implied dedication. I believe the more apt analysis recognizes that the highway-by-user statute is simply a legislative modification of the common law of prescriptive easement. However, I also disagree with the majority’s treatment of Eager v State Hwy Comm’r, 376 Mich 148; 136 NW2d 16 (1965). I do not think that Eager can be harmonized with today’s holding. Therefore, I would explicitly overrule Eager and, in light of the reliance the people of this state must be able to place in the decisions of this Court, apply my ruling prospectively. Consequently, plaintiffs, who acquired their parcel of land in 1973, should be compensated for the strip of land forming the basis of the instant controversy.

At issue here is a strip of land lying adjacent to an improved road that was created by user. That is to say, the road was never formally dedicated to the public as such, but instead was created when the *668public used this portion of land as a road over an extended period. The city of Kentwood has endeavored to widen the road, and in doing so found it necessary to take a portion of defendants’ land for that purpose. However, in determining the amount of compensation owed defendants because of the taking, plaintiff has claimed that it need not pay compensation for any portion of the existing highway and that its existing right of way is four-rods wide, despite the fact that the improved portion of the road did not extend that far onto defendant’s land. Defendants, in turn, argue that they must be compensated for all the land taken that lies outside the existing improved portion of the road because a highway by user is only as wide as actually used, not four rods. The trial court agreed with defendants and ordered that they be compensated for all land taken that lies outside the improved portion of the road. This Court granted leave to appeal, bypassing the Court of Appeals, in order to address the question presented.

As noted initially, I believe the highway-by-user statute is simply a legislative modification of the common law of prescriptive easement. An easement, put simply, is the right to use the land of someone else. Morrill v Mackman, 24 Mich 279, 297 (1872). Our common law recognizes the creation of easements through prescription. Prescriptive easements are created when a person uses the property of another for a particular purpose, but does not possess the land. “Title or rights in lands founded on prescription originate from the fact of actual, adverse, peaceable, open, and uninterrupted possession for such length of time that the law presumes that the true owner, by his acquiescence, has granted the land, or interest to the *669land, so held adversely.” Turner v Hart, 71 Mich 128, 138; 38 NW 890 (1888). At common law, the party claiming the easement must have used it for fifteen years. Id.

With this understanding of the common law of prescriptive easement, I turn to the statute in question. As noted by the majority, the Legislature first addressed highways created by use in 1838 RS, tit 6, ch 4, § 42. Enacted the year after Michigan became a state, it provided that “all roads not recorded, which have been, or shall have been used as public highways twenty years or more, shall be deemed public highways . . . .” Section 43 in turn required that all roads that had been used as public highways for at least twenty years be opened to at least two rods in width.

Before the enactment of this statute, in the early days of our state, many roads were informally established. Under the common law, such use would appear to have created an easement across the land because it was actual, adverse, peaceable, open, and uninterrupted. However, at common law an easement in gross normally flowed to a specific individual and was limited in scope to actual use. In moving forward with the business of governing a new state, the Legislature sought to regularize the system of public highways. Consequently, it determined that such informally created roads should attain a legally recognized status and formally become public highways. Modifying the common law of easement, clearly within the Legislature’s prerogative, Const 1963, art 3, § 7; Placek v Sterling Heights, 405 Mich 638, 657; 275 NW2d 511 (1979), the Legislature vested the rights to use these roads in the public at large and determined that the *670roads must have been used for twenty, rather than fifteen years, before they would attain such status. Additionally, while common-law easements were limited to the scope of actual use, the Legislature determined that public highways would be at least two rods, or thirty-three feet, wide. 1838 RS, tit 6, ch 4, § 43.

In subsequent years the Legislature modified the statutes related to highway by user, changing the period of prescription from twenty years to ten and also expanding the width of the easement created from two rods to four. Nevertheless, the basic statutory scheme remains unchanged. Consequently, § 20, the present incarnation of the highway-by-user statute, provides in part:

[A]ll roads that shall have been used as such for 10 years or more, whether any record or other proof exists that they were ever established as highways or not, and all roads which have been or which may hereafter be laid out and not recorded, and which shall have been used 8 years or more, shall be deemed public highways, subject to be altered or discontinued according to the provisions of this act. All highways that are or that may become such by time and use, shall be 4 rods in width ....

This Court has recognized that the right of way obtained pursuant to the highway-by-user statute is an easement and that the abutting landowner retains the fee simple interest. Eyde Bros Development Co v Eaton Co Drain Comm’r, 427 Mich 271, 282; 398 NW2d 297 (1986); cf. Grandville v Jenison, 84 Mich 54, 65; 47 NW 600 (1890); Wanzer v Blanchard, 3 Mich 11, 16 (1853). Because the nature of the interest obtained by the public is an easement that was created essentially by prescription, in order to remove *671any confusion in the future in this regard, I would clarify the analysis accordingly. Moreover, acknowledging that the state has only obtained an easement answers Justice Weaver’s concern that the highway-by-user statute “destroys a fee simple interest in real property without compensation . . . .” Post at 682. This is simply not the case because the fee is retained by the abutting landowner. Only an easement is created by the highway-by-user statute.

My dissenting colleagues conclude that granting the state a right of way that exceeds the amount actually used effects a taking of the abutting landowner’s property without just compensation, in violation of US Const, Am V and Const 1963, art 10, § 2. I disagree. First, as just noted, the landowner retains his fee simple interest. Second, because the right of way, as a prescriptive easement, would not have attained status as a highway by user but for the abutting landowner’s acquiescence in the use of a portion of his land as a highway, the landowner’s acquiescence precludes any finding of a taking. Third, we must acknowledge what I believe to be the controlling effect of the United States Supreme Court’s jurisprudence in this area.

My dissenting colleagues assert that the landowner did not acquiesce to anything more than what was actually used, as would be the case if one were addressing a common-law prescriptive easement. However, this view ignores that the highway-by-user statute puts the landowner on notice that if he allows a highway to be created by use, the highway will be the statutory width, absent some action by the landowner to eliminate or limit the use of his land that *672operates, over the prescriptive period, to create the highway by user.

My colleagues argue that statutory notice alone cannot be sufficient to apprise the landowner that acquiescence in a road ten feet wide is actually acquiescence in a road four-rods wide. I disagree. As the majority notes, both this Court and the United States Supreme Court have found that the titleholder of mineral rights may lose those rights for failure to specifically claim them, even where the only notice of the need to file the statutory claim is in the statute itself. As noted in Texaco v Short, 454 US 516, 532; 102 S Ct 781; 70 L Ed 2d 738 (1982):

It is well established that persons owning property within a State are charged with knowledge of relevant statutory provisions affecting the control or disposition of such property.

See also North Laramie Land Co v Hoffman, 268 US 276, 283; 45 S Ct 491; 69 L Ed 953 (1925); Van Slooten v Larsen, 410 Mich 21, 52-55; 299 NW2d 704 (1980); Curley v Beryllium Development Corp, 281 Mich 554, 556; 275 NW 246 (1937) (“It is a maxim of the law that ‘ignorance excuses no one’ ”).1

*673That the effectiveness of the statutory notice was sufficient in this case, regarding property interests, is buttressed by the fact that the presumption of knowledge of the law applies equally to the situation in which a person’s liberty, rather than property, interests are at stake, i.e., a situation historically subjected to more exacting judicial scrutiny. See United States v Carotene Products Co, 304 US 144, 153, n 4; 58 S Ct 778; 82 L Ed 1234 (1938). It is firmly grounded in our law that a person may have his liberty interests taken away, in the form of imprisonment, for violating a statute of which he did not have actual knowledge. “The general rule that ignorance of the law or a mistake of law is no defense to criminal prosecution is deeply rooted in the American legal system.” Cheek v United States, 498 US 192, 199; 111 S Ct 604; 112 L Ed 2d 617 (1991); see also People v Motor City Hosp & Surgical Supply, Inc, 227 Mich App 209, 215; 575 NW2d 95 (1997). With this understanding it is clear that the enactment and publication of the highway-by-user statute is sufficient to put landowners on notice that acquiescence in the creation of a highway by user across their land will create a right of way four rods in width even if less is actually used.

Finally, in its discussion of Nollan v California Coastal Comm, 483 US 825; 107 S Ct 3141; 97 L Ed 2d 677 (1987), the dissent misapprehends that the easement there under discussion was a specific easement over the Nollan’s land. The California Coastal Commission had, as described colorfully by Justice Scalia, through an “out-and-out plan of extortion,” condi*674tioned the issuance of a building permit on the Nollan’s granting of an easement over their land. Id. at 837. Unsurprisingly, this was held to be a taking. Our situation is not analogous, because the highway-by-user statute does not grant a specific easement, or indeed any easement at all, it merely alters the common-law requirements for establishing an abandonment so that an easement may be held to be established. Thus, for example, what was at common law a fifteen-year use requirement was modified by the statute to ten years. This ability of the Legislature to modify the common law of easement is, as I understand the dissenters, not contested. What is contested, however, is the kind and scope of modification the Legislature can make. It is clear that the dissenting justices do not believe that the power to modify the common law can extend to the size of the easement granted. Were this question a matter of first impression, much could be said for their position. This question, however, is not one of uncertainty in our law, because it has been settled by the United States Supreme Court in Texaco. In that case, it was held that if notice is given by statute (as it was here) the affected interests in land (a fee interest in minerals in Texaco) can be shifted in this fashion. Our case is easier and falls within the Texaco rule. After all, rather than shifting a fee interest, the highway-by-user statute only claims a right to travel over the fee, which is, of course, a deprivation less than the total termination of a fee interest such as that seen in Texaco. We should follow Texaco and find that there was no taking. It is our duty to follow the precedent of the United States Supreme Court on this constitutional matter, no matter what our own predilections, or give *675legally recognizable reasons for not doing so. Those reasons have, to my eye, not been presented.

Moreover, we must also recognize this Court’s decision in Eager, supra at 154, which held:

We agree with the trial court that privately owned land cannot become public road by user beyond the portion used as such merely by the above noted statutory pronouncement to that effect. To so hold would be violative of Constitution of 1850, art 18, § 14, Constitution 1908, art 13, § 1, which prohibited taking by the public of private property except upon determination of necessity and just compensation “being first made and secured.”

In light of this specific holding, the majority’s attempt to harmonize Eager with today’s holding simply is not possible.2 If we are going to assume that people have read and know the law, one could only conclude that *676after Eager was decided everyone should have understood that a highway by user is only as wide as is actually used. Yet, I am convinced that Eager was wrongly decided. Consequently, because both my conclusion and the conclusion of the majority overrules this established precedent, we must consider the effect of our decision.

When Eager was decided, its effect was to make the portion of the highway-by-user statute that gave more land to the prescriptive user than was actually being used unconstitutional. This holding was retroactive under the doctrine that a statute, or portion of a statute, that is unconstitutional was always, from its inception, “inoperative as though it had never been passed.” Norton v Shelby Co, Tennessee, 118 US 425, 442; 6 S Ct 1121; 30 L Ed 178 (1886); see also Briggs v Campbell, Wyant & Cannon Foundry Co, 379 Mich 160, 165; 150 NW2d 752 (1967). Accordingly, the nonused portion of the four rods was never in any fashion subject to any claim of prescriptive easement. Thus, with respect to the instant dispute, I believe the trial court did not err in ordering that the city of Kentwood must compensate defendants for all land taken from them that lies outside the established use.

However, by revivifying the statute, we today make all land abutting a highway created by user subject to the creation of an easement of the statutorily presumed width. Because today’s holding “overrules settled precedent,” we should give it prospective application only. Lindsey v Harper Hosp, 455 Mich 56, 68; 564 NW2d 861 (1997). This would mean that the greater amount of land that the statute allows to be used by way of easement could be secured if the prescriptive period of the statute runs from this time for*677ward and the fee holder does not act to manifest lack of acquiescence in such use.

The dissenters attempt to read Texaco and Van Slooten, supra, to say that the statute here at issue, which gives ten years before the abandonment necessary to establish an easement occurs, runs afoul of a constitutional requirement in Texaco and Van Slooten to the effect that at least twenty years must be given to the affected landowner to act to preserve his interest. This is incorrect, as Texaco and Van Slooten not only do not establish such a twenty-year floor, but in fact, in finding the statutes constitutional approved a two-year grace period in Texaco and a three-year grace period in Van Slooten in which owners of interests created before the acts were passed had to record a claim of interest to preserve their mineral rights. Texaco, supra at 518-519; Van Slooten, supra at 38. The position of the Van Slooten majority was that such notice rules are tested not for some arbitrary time requirement, but by a rule of reason. Van *673Slooten, supra at 49. Because two and three years were reasonable for the total divestment of an interest, certainly ten years to establish the less draconian circumstance of an abandonment must also be here.

I disagree with the majority’s conclusion that the decision in Eager was based on the conclusion that the statutory presumption of width had been rebutted within the period of prescription. Close scrutiny reveals that the road at issue in Eager was created in 1872. The action (widening of the road) initiating the lawsuit occurred in 1958. Id. The opinion discusses testimony going “a half-century back” regarding the uses that had been made of the contested land. Because this evidence did not go back far enough to reach the period of prescription, logically this Court’s holding could not have been based on the assumption that the statutory presumption had been rebutted during the period of prescription, which would have ended before the events that were adduced through testimony at trial. Moreover, since 1907, the Legislature has determined that an abutting landowner may not acquire any rights in a public highway through action that would, at common law, have constituted adverse possession. See Crosby v Greenville, 183 Mich 452, 459; 150 NW 246 (1914); MCL 247.190; MSA 9.270. Consequently, it must be that the Court’s ruling was based on its conclusion that a highway by user is only as wide as actually used. This view of Eager is not idiosyncratic as the decisions of other jurisdictions as well as commentaries have understood this to be its holding. See Barfnecht v Town Bd of Hollywood Twp, Carver Co, Minnesota, 304 Minn 505; 232 NW2d 420 (1975); Keidel v Rask, 304 NW2d 402 (ND, 1981); 76 ALR2d 535; 76 ALR2d Later Case Service, § 4, pp 393-394; 39 Am Jur 2d, Highways, Streets & Bridges, § 52, p 440; 2 Cameron, Michigan Real Property Law (2d ed), Principles & Commentary, § 25.9, p 1162.