Goodson v. Ford
290 Ga. 662
| Ga. | 2012Background
- Three adjacent rural Lee County properties: Goodsons/Ellers (Appellants) and Ford (Appellees).
- Carol Street is a 60x418 ft strip shown on a subdivision plat originally for Allen Acres; later withdrawal of plat occurred.
- Deeds and chain of title reference the Allen Acres plat, with streets designated as Carol Street or Road.
- Ford Property (38.63 acres) includes Carol Street; 2007 petition to quiet title; trial court held a 20-foot easement for ingress/egress only.
- Special master found limited use (ingress/egress only) with no adverse possession; trial court adopted findings and denied broader rights.
- Appellants appealed; court affirmed, upholding 20-foot easement and rejecting adverse possession and broader title to Carol Street.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellants acquired title by adverse possession. | Appellants claim 20+ years of adverse use. | Use was permissive, non-adverse; no notice. | Adverse possession claim rejected; factual record presumptively supported. |
| Whether appellants hold legal title to Carol Street via express grant from the Allen Acres plat. | Plat created an express grant of Carol Street. | Plat withdrawal and estoppel negate express grant; easement remains. | Appellees retain only an easement, not legal title. |
| Whether the Allen Acres plat created a full 60-foot easement for reasonable enjoyment. | Full platted width required for reasonable enjoyment. | Only necessary 20-foot width needed for ingress/egress. | Court limited to a 20-foot easement; full width not required. |
| Whether unclean hands precludes Ford’s quiet title relief. | Ford had notice of other uses before purchase. | No sufficient prejudice or inequity; unclean hands absent. | Unclean hands not established; relief not barred. |
| Whether laches defeats Ford’s quiet title claim. | Appellants delayed actions and prejudice may arise. | No prejudicial change in circumstances; delay not constitutive of laches. | Laches not proven; relief permitted. |
Key Cases Cited
- Sadler v. First Nat. Bank of Baldwin County, 267 Ga. 122 (1996) (subdivision streets presumed dedicated for use; easement by express grant)
- Stanfield v. Brewton, 228 Ga. 92 (1971) (irrevocable dedication of streets when plat recorded)
- Zywiciel v. Historic Westside Village Partners, LLC, 313 Ga. App. 397 (2011) (estoppel against denial of streets designated in plat)
- Smith v. Bruce, 241 Ga. 133 (1978) (first subdivider estopped from denying streets designated for common good)
- Pleasure Bluff Dock Club, Inc. v. Poston, 294 Ga. App. 318 (2008) (easement purposes and reasonable enjoyment under plat)
- Georgia Power Co. v. Leonard, 187 Ga. 608 (1939) (grant of express easement permits reasonable limitation for enjoyment)
- Montana v. Blount, 232 Ga. App. 782 (1998) (rebuttable presumption of full use for easement)
- SRB Inv. Svcs., LLLP v. Branch Banking & Trust Co., 289 Ga. 1 (2011) (laches requires prejudice; delay alone not enough)
- Pryor v. Pryor, 263 Ga. 153 (1993) (equitable relief requires conscience not violated)