Prout v. Department of Transportation
Facts: A land developer dedicates a highway-adjacent parcel of land to the California Department of Transportation (Caltrans) in order to connect the highway to a road on their development. The parcel is never formally deeded to Caltrans, but the developer notes the dedication and provides their signature on a subdivision map of the area sent to Caltrans. Later, Caltrans sends the developer a grant deed to sign in order to formally transfer the parcel to Caltrans. The developer does not sign the deed. Caltrans begins work on highway improvements on the parcel.
Claim: The developer seeks monetary compensation for the value of the land Caltrans occupied, claiming they had no right to use the parcel for highway improvements since the developer never formally deeded the parcel to Caltrans.
Counter claim: Caltrans claims they had a right to use the parcel for highway improvements since the developer never rescinded or objected to their dedication of the parcel and Caltrans accepted the developer’s offer of dedication by occupying the parcel.
Holding: A California court of appeals holds the developer may not receive monetary compensation for the parcel since Caltrans accepted the developer’s offer of dedication by occupying the parcel. [Prout v. Department of Transportation (December 18, 2018) _CA6th_]
