County of Yuma v. Leidendeker
In County of Yuma v. Leidendeker, 81 Ariz. 208, 303 P.2d 531 (1956), the owner of a forty-acre parcel had recorded a plat that subdivided a property into ten blocks. A reference on the plat stated one block was dedicated to the public for use as a park.
Over forty years later, the block's successor owner filed a quiet title action, seeking to have the dedication declared ineffective or the public's interest deemed abandoned.
In addressing the applicability of 9-254's predecessor, the supreme court concluded that, based on the statutory scheme, the legislature had intended it to apply only to property either within a municipality or adjacent to and part of a proposed addition thereto. Because the property had been neither at the time the plat was recorded, the court held the statute did not apply.