Sayers v. Chouteau County

369 Mont. 98, 2013 MT 45 (2013) · Supreme Court of the State of Montana · February 27, 2013 · No. DA 12-0340

Summary

The Montana Supreme Court affirmed summary judgment for Chouteau County in a dispute over whether the entire length of Lippard Road constituted a public county roadway. Applying the framework from Reid v. Park County, the Court held that the record as a whole established the contested section of the road as public and found no evidence that the County had abandoned it.

Holdings

  1. The Reid analysis applies when the parties dispute whether a historically established county road was validly created and the public record is old, incomplete, or uncertain; the district court properly considered the record as a whole.
  2. The entire contested section of Lippard Road extended past the Section 26 and 27 intersection to the railroad right-of-way and was established as a public county road.

Questions Presented

  1. Whether the District Court properly applied the whole-record analysis from Reid v. Park County to determine whether Lippard Road constituted a public roadway.
  2. Whether the District Court properly determined that the entire length of Lippard Road, including the contested section beyond the Section 26 and 27 intersection, constituted a public roadway.

Disposition

affirmed

Cases Cited (9)

  • Reid v. Park County, 192 Mont. 231, 627 P.2d 1210 (1981)(followed)
  • State v. Butte-Silver Bow County, 2009 MT 414, 353 Mont. 497, 220 P.3d 1115(followed)
  • Galassi v. Lincoln County Board of Commissioners, 2003 MT 319, 318 Mont. 288, 80 P.3d 84(followed)
  • Warren v. Chouteau County, 82 Mont. 115, 265 P. 676 (1928)(followed)
  • Garrison v. Lincoln County, 2003 MT 227, 317 Mont. 190, 77 P.3d 163(followed)
  • Prindel v. Ravalli County, 2006 MT 62, 331 Mont. 338, 133 P.3d 165(distinguished)
  • Apple Park, LLC v. Apple Park Condominiums, 2008 MT 284, 345 Mont. 359, 192 P.3d 232(followed)
  • State v. Fisher, 2003 MT 207, 317 Mont. 49, 75 P.3d 338(followed)
  • McCauley v. Thompson-Nistler, 2000 MT 215, 301 Mont. 81, 10 P.3d 794(followed)

Cited In (0)

No citing cases on record yet.

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