Archenhold Auto Supply Co. v. City of Waco
In Archenhold Auto Supply Co. v. City of Waco, 396 S.W.2d 111 (Tex. 1965), the court found that construction of the South 17th Street viaduct did not deprive the property owner of reasonable access. See 396 S.W.2d at 114.
Located at the intersection of South 17th Street and Franklin Avenue, the property accessed two public roads and a public alley. Id. at 113.
After construction of the viaduct, the building accessed only one public road, Franklin Avenue, and two alleys. Id.
Adopting the rule from New York courts, the court concluded that "one of two public streets may be closed without compensation to an abutting landowner if the remaining street furnishes suitable means of access." Id. at 114.
The court reasoned that because Archenhold retained access to one public street, the property was not materially and substantially impaired. See id.