Island Industrial, LLC v. Town of Grand Isle

Summary

The Vermont Supreme Court affirmed judgment on the pleadings for the Town of Grand Isle in a dispute over the proposed acceptance of a private road as a public road. The court held that the selectboard's 2016 motion did not constitute unequivocal acceptance and therefore did not impose a ministerial duty enforceable by mandamus. The court also held that the trial court properly considered the Rule 12(c) motion without converting it into a summary-judgment motion.

Holdings

1. The trial court did not abuse its discretion by considering the timely motion for judgment on the pleadings because it could efficiently dispose of the case based on the pleadings and no abuse of discretion or prejudice was shown.
2. The motion for judgment on the pleadings was not converted into a summary-judgment motion because the trial court disregarded the extrinsic materials and ruled solely on the pleadings.
3. The complaint did not establish a clear ministerial duty requiring the Town to accept Island Circle as a public road because the 2016 selectboard motion did not demonstrate an unequivocal intent to accept the dedication.
4. The Town's 2018 rescission did not constitute an arbitrary abuse of power because the 2016 motion imposed no affirmative legal duty to accept the road and the Town retained discretion regarding acceptance.
5. Island Industrial was not entitled to mandamus relief based on promissory estoppel because reliance damages were an available remedy, so enforcement of the alleged promise was not the only means of avoiding injustice.

Questions Presented

1. Whether the trial court abused its discretion by considering the Town's motion for judgment on the pleadings rather than the previously filed summary-judgment motion.
2. Whether the trial court was required to convert the Rule 12(c) motion into a summary-judgment motion because matters outside the pleadings were presented.
3. Whether the complaint alleged facts establishing a clear ministerial duty requiring the Town to accept Island Circle as a public road.
4. Whether the Town's rescission of the 2016 motion constituted an arbitrary abuse of power permitting mandamus relief.
5. Whether promissory estoppel required enforcement of the Town's 2016 motion through mandamus.

Disposition

affirmed