Does the Word Word ''Park'' Indicate a Statutory for Use As a Public Park ?
In Emalfarb v. Krater, 266 Ill. App. 3d 243, 203 Ill. Dec. 666, 640 N.E.2d 325 (1994), this court reviewed a trial court ruling that the word "Park" written on a piece of property on a recorded plat constituted a statutory dedication of the subject property to a county for use as a public park and that the dedication was sufficient to render invalid a subsequent tax deed that was issued for the subject property.
The court concluded that the mere word "park" on a plat was not sufficient to indicate a donative intent in the absence of a specific designation of the land as public and without the county specified as the grantee. Emalfarb, 266 Ill. App. 3d at 256.
In Emalfarb, the question the court decided was whether the alleged statutory dedication conveyed land to a public entity for use as a public park.