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ST0301-CS051206I ~3uzan 'taylor- RE: pREscRIPTIVF: RIGH'F[C)F-W~Y Page 1 I From: To; Date: Subject: "James L. Brittain, R.P.L.S." <jlb@brittain-crawford.com> "Suzan Taylo¢' <staylor@ci.coppell.tx.us> 12/6/2005 8:34:35 AM RE: PRESCRIPTIVE RIGHT-OF-WAY SUSAN, THE REASON I DON'T KEEP OR QUOTE STATUTES IS BECAUSE ATTORNEYS FROWN UPON NON-ATTORNEYS PRACTICING LAW. IT IS ESSENTIAL THAT YOU CONSULT THE CITY ATTORNEY ON THESE MATTERS SO THAT YOU NOR I ARE PROVEN WRONG. THESE ARE SIMPLE MATTERS FOR A GOOD ATTORNEY WHO KNOWS THE INDEXING OF VENON'S ANNOTATED CIVIL STATUES, AND CAN FIND THE ACTUAL STATUTE YOU DESIRE. OFTEN TIMES THE LAND OWNER HAS ALREADY CONTACTED THEIR ATTORNEY WHEN THEY ASK THE QUESTION, AND YOU COULD BE EMBARASSED WHEN THEY ALREADY HAVE THE ANSWER. ACCORDING TO "BLACK'S LAW DICTIONARY" TO CREATE AN EASEMENT BY "PRESCRIPTION" THE USE MUST HAVE BEEN OPEN, CONTINUOUS, EXCLUSIVE, AND UNDER CLAIM OF RIGHT FOR STATUTORY PERIOD. AS YOU CAN SEE, AS IN OTHER LAWS, INTERPRETATION OF THE LAW IS THE KEY. YOUR CITY ATTORNEY SHOULD GIVE YOU THE TOOLS YOU NEED TO SPEClCALLY ADDRESS THE LANDOWNERS QUESTIONS. IF YOU DO GET SOME ACTUAL STATUTES FROM HIM, WOULD YOU COPY ME SO I CAN HAVE THEM ON FILE AS WELL. THE LAST TIME I HAD TO GET THE STATUTES WAS OVER FIFTEEN YEARS AGO, AND I HAD TO PAY MY ATTORNEY TO FIND THEM. EVEN WHEN I HAVE LEGAL QUESTIONS, I CALL HIM SO THAT I WILL BE QUOTED CORRECTLY. GOOD LUCK AND KEEP IN TOUCH. JAMES L. BRITTAIN, R.P.L.S. ..... Original Message ..... From: Suzan Taylor [mailto:staylor@ci.coppell.tx.us] Sent: Monday, December 05, 2005 4:38 PM To: R.P.L.S. James L. Brittain Subject: Re: PRESCRIPTIVE RIGHT-OF-WAY I appreciate your help. I am writing letters to the property owners and trying to explain prescriptive rights. The City Engineer said that he had seen the statute at one time and wanted me to see if I could find a copy. Suzan Taylor >>> "James L. Brittain, R.P.L.S." <jlb@brittain-crawford.com> 12/05/05 4:03 PM >>> PRESCRIPTIVE RIGHT-OF-WAY MANY ORIGINAL DEEDS RUN TO THE MIDDLE OF THE ROAD, ESPECIALLY OLD COUNTY ROADS. BEFORE CITIES, AND COUNTIES WERE MORE ORGANIZED, AND REQUIRED RECORDED RIGHT-OF-WAY DOCUMENTS, ROADS WERE BUILT TO ACCOMMODATE THE ADJOINING LAND OWNERS TO ALLOW COMMERCE BETWEEN ONE ANOTHER AND [ Suzan ,~ylor - RE: PRESCRIPTIVE RIGHT-OF-WAY Page 2~ COMMUNITY CENTERS. THESE ROADS MORE LIKELY THAN NOT DID NOT HAVE AN OFFICIAL GRANT OF THE RIGHT-OF-WAY AREA CONVEYED TO THE COUNTY OR CITY THAT INHERITED THE MAINTENANCE OF THE ROAD AND IT'S DRAINAGE FACILITIES (CULVERTS, DITCHES, ETC.). WHEN A CITY OR COUNTY HAS MAINTAINED THIS ROAD OR THE PUBLIC (EVEN IF IT IS ONLY ONE NEIGHBOR) HAS BEEN ALLOWED TO USE THIS ROAD FOR A PERIOD OF TIME (LETS SAY SlX MONTHS OR LONGER) FOR ACCESS (VEHICULAR OR WALKING OR STAGECOACH, ETC.)IT BECOMES A PRESCRIPTIVE RIGHT. THE LIMITS OF THE PRESCRIPTIVE RIGHT-OF-WAY VARIES, BASED UPON WHAT THE CITY OR COUNTY HAS MAINTAINED, OR THAT THE ADJOINING LAND OWNER HAS UNDER FENCE. WHEN THE CITY OR COUNTY MAINTAINS A ROAD THE BORROW DITCHES ON EACH SIDE ARE INCLUDED TO THE LIMITS OF THE LAND OWNERS SIDE OF THE TOP BANK. IF AN ADJOINING LAND OWNER DECIDED TO FENCE THEIR PROPERTY TO THE CENTER OF THE ROAD, EFFECTIVELY BLOCKING ALL TRAFFIC FROM PASSING OVER THE AREA FORMERLY USED FOR PUBLIC PASSAGE, THIS WOULD CAUSE THE DAILEY COMMERCE TO BE DISRUPTED, AND CITIZEN'S RIGHTS TO BE PLACED AT RISK. THIS CUSTOM OF PRESCRIPTIVE RIGHTS-OF-WAY AND THEIR USE AND MAINTENANCE HAS BEEN AROUND SINCE ROMAN TIMES. PLEASE PASS THIS OPINION TO YOUR CITY ATTORNEY FOR HIS INPUT, AND GET HIM TO PROVIDE ACTUAL STATUTES IF NECESSARY. I HOPE THAT I HAVE HELPED YOU UNDERSTAND THE EXTENT, AND VALUE OF THE UN-RECORDED PRESCRIPTIVE RIGHT-OF-WAY. RESPECTFULLY SUBMITTED JAMES L. BRITTAIN, R.P.LS. CC: <thh@freese.com>