Beach v. Lima Township, 489 Mich. 99

Harford Village plat (1835) shows platted streets North, East, and Cross, not developed, within blocks II–III of six-block plat.
Beach family claimed ownership to Blocks II and III; township owned Block I and used part for a community hall and planned a fire substation.
Dispute centers on whether plaintiffs could quiet title to platted streets by adverse possession without filing under the LDA.
Circuit court granted summary disposition recognizing adverse possession and ordered plat correction to remove disputed streets, though plaintiffs did not request LDA relief.
Court of Appeals affirmed; held LDA filing was not required because plaintiffs did not expressly seek to vacate/correct/revise the dedication in the plat.
This Court held that adverse possession quiet title establishes a substantive right and need not proceed under the LDA; the circuit court’s plat-correction order must be struck as unrequested relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether adverse possession quiet title can establish marketable title without LDA	Beach argues no LDA filing required; quiet title suffices.	LDA is exclusive for plat alterations and should have been used.	No LDA filing required; quiet title action proper to establish title.
Whether LDA is the exclusive means to vacate, correct, or revise a plat	LDA not necessary when rights arise independently of plat.	LDA is exclusive for any plat alteration.	LDA is exclusive for vacating/correcting/revising a plat; but here plaintiffs’ right arose independently, so no LDA prerequisite.
Whether the circuit court could order plat correction without LDA	Courts may correct plat as part of recognizing title by quiet title.	Correction requires LDA procedures and notice.	Circuit court erred in ordering plat correction; strike that portion; LDA procedures apply if relief sought.

Beach v Lima Twp, 473 Mich? (placeholder) (unprovided) (this entry placeholder is not allowed; please provide correct citations)