Paris v. County of Santa Clara

In Paris v. County of Santa Clara (1969) 270 Cal. App. 2d 691, an offer of dedication was made and rejected. More than 25 years later, the County purported to accept the offer. The owners of the property did not learn of the County's action until construction began on the highway for which the land was being used. The owners brought an inverse condemnation action against the County. (Paris at p. 692.) They asserted that the conclusive presumption precluded the County from accepting the offer of dedication at that point. (Paris at p. 694.) The trial court decided that the owners were not entitled to the benefit of the conclusive presumption because they had not brought a quiet title action prior to the County's action purporting to accept the offer. (Paris at p. 698.) On appeal, the Court of Appeal rejected the County's contention that the conclusive presumption was only available in a quiet title action. "The statute does not state that the conclusive presumption arises only in the event the plaintiff commences a quiet title action but provides that it shall arise upon the expiration of the 25-year period and that the plaintiff may bring a quiet title action and avail himself of such presumption. The statute fails to enumerate any circumstances under which the conclusive presumption, once having arisen, may be overcome . . . . The sole question remaining is whether a property owner who meets all the other requirements . . .,but who commences an action in inverse condemnation rather than a quiet title action, loses his right to rely upon the conclusive presumption of nonacceptance by the governmental entity. Such a distinction would be arbitrary and unreasonable, and it is the rule that where two possible interpretations of a statute are presented, the court should adopt the interpretation producing the most reasonable result. Moreover, as above noted, the statute contains no language indicating an intent that the presumption apply only in a quiet title action or that the existence of the presumption is in any way dependent upon the bringing of such an action." (Paris at pp. 698-699.)