Biagini v. Beckham

In Biagini v. Beckham (2008) 163 Cal.App.4th 1000, the Court explained that under the common law, an offer of dedication can be accepted by the public's use of the area dedicated -- in Biagini, a road. (Id. at p. 1012.) In the course of explaining that point, we noted that "'dedication is a matter purely between the owner and the public. There is no such thing as a dedication between the owner and individuals. The public must be a party to every dedication.'" (Ibid.) The Court then went on to find that use of a road that was consistent with a corresponding private easement provided "no basis for finding an implied acceptance of an offer of dedication by public use." (Biagini, at pp. 1013-1014.)