Coppinger v. Rawlins
Facts: An owner of vacant land subdivides their lot into two parcels, one of which becomes landlocked, and dedicates a portion of each parcel to the county for a public road to access the parcels. The county accepts the dedicated portions, but does not designate them for county maintenance. Several years later, both parcels are purchased by two separate owners. The owner of the landlocked parcel uses the road to access their property. Another neighbor on the opposite side of the road also begins using the road to access their property. The owner of the landlocked parcel erects a gate around the road to prevent the neighbor’s access.
Claim: The owner of the landlocked parcel seeks money losses for trespassing from the neighbor and quiet title to the portion of the parcel used as the road, claiming the county’s decision not to designate the road for county maintenance indicates the dedicated portion of the parcel was not absolutely accepted and thus the neighbor’s use of the segment is trespassing.
Counterclaim: The neighbor seeks use of the road, claiming the county’s acceptance of the dedicated portion of the parcels prior to the owner’s purchase of the landlocked parcel indicates the road is reserved for public use regardless of designation for county maintenance.
Holding: A California court of appeals holds the county’s acceptance of the dedication of the portion of the parcels is complete regardless of designation for county maintenance and thus the owner of the landlocked parcel is not entitled to money losses or quiet title since the exception of the road from county maintenance does not preclude the road from public use by the neighbor. [Coppinger v. Rawlins (2015) 239 CA4th 608]
