HomeMy WebLinkAboutM-78-0657tot
A STUDY OF TRANSIT ALTERATIVE ALIGNMENTS
AND THEIR IMPACT ON THE
GOVERNMENT CENTER AREA
OFFICE OF TRANSPORTATION ADMINISTRATION
August 14, 1978
r78-657
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1111111111111111111111111111111111111EMMEmiumm
TO.
Mayor and Members of
City Commission
Joseph Re Grassier
City Manager
r•( ^r MIAMI. '-..<?aIDA
rliSry.,}"-{C _ Ni5MORANOUM
,..T' OCT 2 1g78
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rlicLcsunts:
Attached for your review is a recent Dade County report entitled
"A Study of Transit Alternative Alignments and their Impacts on
the Government Center Area".
The proposed east -west phase II of the Rapid Transit System will
cross the presently designed phase I alignment at the Government
Center Station. Tit:_' design of the Government Center Station that
is now underway must incorporate the best alternative crossing.
A presentation to the Commission on these alternatives will be made
by Dade County at the October 24th Commission meeting. The county
report favors alternative No. 3 which has a diagonal alignment
through the Govern�Center
forand
thearo�teection north tos163rdof tStreeternment
Center to the FEC ailroad
It should be noted that Mr. Geddes October 17th report to the County
Commission on the master plan for the Government Center recommended
a straight Phase II crossing of the Government Center along NW
2nd Street which implies that alternative No. 2 may be the most
compatible with the objectives of the Government Center plan.
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011 COURTHOUSE
MIAMI, FLORIDA 33130
TEL: 579-5311
6FFICE OF COUNTY MANAGER
Richard Fosmoen
Assistant City Manager
City of Miami Planning Department'
3500 Pan American Drive
Miami, Florida 33131
CEP 2 8 i278
Dear Mr. Fosmoen:
Attached for your review and comment is a recently completed report
entitled "A Study of Transit Alternative Alignments and their Impact on
the Government Center Area". This report was needed to facilitate un-
interrupted progress in the design of the Government Center complex.
Since the design of the remaining buildings in the Government Center
complex is underway, space allocations for all transit related facili-
ties must be made as quickly as possible. Therefore, this report was
designed to promote suggested alternatives and elicit comments from
interested groups.
The report recommends that alternative alignment concept No. 3 be
adopted for future planning. This alternative causes the least disruption
through the Miami CBD, and also provides a service connection between the
Stage 1 rapid transit system and future rail extensions. This makes a
second multi -million dollar maintenance yard and shop site unnecessary,
and would reduce future costs and speed-up development of new extensions.
It also provides for transfers among Stage 1, future rail extensions,
and the DPI system at one central location.
If you have any comments with regard to this report, please contact
Fred Silverman at 579-5672 or myself.
ncerely,
John A. Dy
Transport. ion Coordinator
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;:!'? OF *•iIA► I. �'LO ztr n
i`a I !!!R•OFFICZ:
I TO' Mayor and Members of the ,Ikr
City Commission
:,unJccr
-
Pc,m. Joseph R. Grassie ,. , ~ tm.perEt,cts
m City Manager
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OCT 20 in
C.f;cLZ;U Z=:
The Planning Department, has been under contract to Dade County,
for the past several months to plan the areas around Miami's ten
transit stations, a process known as Station Area Design and de-
velopment (SADD). To date planning staff have completed a de-
scription of existing conditions around these stations and are
publishing the findings in brief reports for each station area.
Copies of the first three reports issued in the City of Miami for
the Douglas Road, Coconut Grove and Vizcaya Stations are attached.
The reports provide the basis for initiating the SADD citizen
participation planning program that is scheduled to begin November.
In addition these documents will provide advance information for
property owners, developers and investors who will be seeking
opportunities for development near transit stations.
The next step in the process will be public hearings before the
Commission this spring on SADD phase II during which alternative
concepts for development in transit station areas will be proposed.
This will result in a refinement of alternatives in a final recom-
mended concept plan (Phase III) in late 1979. These final phase
III plans, if adopted by the City Commission after public hearings,
would govern all public and private development actions in transit
station areas.
This three phase process is described in the Regional Profile
(also attached), which gives a system -wide overview of the SADD
program.
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Of CONIttetS
1 NTKOiJtC T IONi Y i k a, 1 1 i$ i 1► s Y 1 t'i ►, $$ 1 1 4 1
CIE THODOLOGY .. , 1, 1 1 a i i i a►, a i a a a i i a$ a 1 1 1 1 4 1 1$ 1'a 14 1 1 1
INITIAL SCREENING: THE REFINEMENT
OF ALTERNATIVES ,,,,,,,,,,,,,, a
APPLICATIO.: OF EVALUATION CRITERIA i , a a i a i,, 1: 1 i1►4 %
► , 0
y p LEVEL TWO SCREENING OF DESIGN APFPOACHES,
CONCLUSIONS
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The preparation of this report has been financed in part
through a grant from the U.S. Department of Transportation,
Urban Mass Transportation Administration, under the Urban
Mass Transportation Act of 1964, as amended. The opinions,
findings, conclusions expressed in this report are not
necessarily those of the Urban Mass Transportation
Administration.
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tigT OP ?iGURES
tieditotth CoVetnment Centex..,,,.......►►rs.t
Current Alignment of the Stage 1 Rabid
transit System and the Downtown People Mo'Vet.s
8, The Four Basic Alternatives .1.-rt
4. Alternative 1 - East-West Line stub-End......�.+'r`w'
5. Alternative 2 - East-West Line at Right:
Angle,Separated Platforms
6. Alternative 2A - East-West Line at Right
Angle, Connected Platforms , 4 4
7. Alternative 3 - East-West Line at Angle
SW to NE, Separated Platforms . , ► 6 6 6
8. Alternative 3A - East-West Line at Angle
SW to NE,Connected Platforms +6a"'
9. Alternative 4 - East-West Line Turning in
Government Center, Parallel Platforms
10. Alternative 5 - East-West Line Outside
Government Center
11. Alternative 6 - East-West Line through CBD,
Northeast Connection Via NE 2nd Avenue
12. Alternative 7 - East-West Line through CBD,
Northeast Connection Via Washington Heights
13. Summary of Impacts on the Government Center
14. Alternative Design 1 - East-West Line
Stub -End
15. Alternative Design 2 - East-West Line at
Right Angle in Government Center
16. Alternative Design 3 - East-West Line at
Angle SW to NE in Government Center
17. Alternative Design 4 - East-West Line
Outside Government Center
18. The Four Alternative Designs:
Summary of Characteristics
1s
INTRODUCTION
perhaps the most significant long-term public policy
decision the Board of County Commissioners will make during
the next few months is how it decides to fit its fixed guide-
way public transportation facilities with the public buildings
planned for the area generally defined as the Government
Center. The Government Center area consists of more than
33 acres located on the western boundary of the Central Bus-
iness District (CBD).
The reason for the timing of the decisions is that the fixed
guideway transit system is to be built in three or more stages
with the first stage of some 20.5 miles from Dadeland on the
south to Hialeah on the west being under final design at the
present time. Construction on the first stage is to begin
in 1979 with operations to begin in 1983. The designs of
buildingsand the first stage of the transit system are to
the point that the cross or "X" in the system must be defined
in absolute terms and the design frozen so that architects
and engineers of the building facilities and the transit sta-
tion at the Government Center can proceed to complete their
tasks on a timely basis.
The basic rail transit system as either committed or planned
for Metropolitan Dade County consists of at least three major
elements, all of which interface at or near Government Center
in the Miami CBD. These are: (1) Stage 1 -- Hialeah-Dadeland;
(2) East -west line from Little Havana to Northeast Dade; and
(3) Downtown People Mover (DPM) within the Miami CBD.
The focal point of the entire system is the Government Center,
a new complex of County, City, State, and Federal buildings
on the west side of Miami's CBD. The Stage 1 rapid transit
line runs along the east side of the complex over the Florida
East Coast Railroad (FEC) right-of-way. Several buildings
have already been completed, others are under design and still
others are in planning.
The original plan for the Government Center was completed in
1975. The 2000 Site Plan which emerged from the study in 1975
is shown in Figure 1. To avoid future design conflicts, the
1975 master plan for the Government Center is being re-examined
and brought up to date. Completion of this study is proposed
for September or October, 1978. Simultaneously, investigation
of the interface between Stage 1 of the rapid transit system
and future extensions has been initiated to allow Government
Center design decisions to accommodate these extensions and to
modify original Preliminary Engineering concepts regarding
future rapid transit service impacts within the CBD and the
FIGURE 1
bbt4W Ot3N COVE1INMENT CENTER
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ILLUSTRATIVE SITE PLAN 11111 I I I I
year 2000 ° �'�"°�°"°
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toVeththent Center. A toajot change is the Downtown People
'diver (DPM) and its interface with operating rapid transit
lines which was not considered during Preliminary Engineering
of the original Government Center planning.
Compounding these elements are design considerations that require the Stage 1 transit line to accommodate the following.'
(1) Adequate vertical clearance over the Miami River and 1-95;
(2) Harmonious connections to the Government Center complex,
older parts of the CBD, and the DPM; (3) Adequate vertical and
horizontal spacing to allow for locating the Washington Heights
station; (4) Allowance for maintaining a viable Florida East
Coast rail operation; (5) The operation of north -south and
east -west line rail services; and (6) Passenger transfer
between lines.
This report examines the problems and issues regarding future
rail extensions and presents information concerning options
for these extensions, with varying impacts to design standards,
disruption to existing and planned land uses, and service con-
siderations, and relates them to the development of
the
ekGGovern-
ment Center and adjacent areas. Finally,report
s a
recommendation on the most advantageous alternative.
Some of the technical problems which have to be considered
are described in the Kaiser Transit Group's final report,
"Definitive Engineering Study, Line Section 4 Transit Facil-
ities," addressing the question of the Miami River crossing
of Stage 1, and its
impact
resultthe
fromGovernment
KTGCenter
study;station.
Two fundamental problems
1. The lack of service connection between the Stage 1
and future lines could adversely affect system oper-
ations by precluding vehicle transfer from one line
to the other to balance operations, making it necessary
to build a second heavy -maintenance facility serving
only the east -west line (or, alternatively, hauling
vehicles "off-line" to the Hialeah yard for mainten-
ance) .
Lack of revenue connection between the east -west
line and the northeast Dade line would result in a
system consisting of three lines, two of them ter-
minating at or near Government Center, exacerbating
problems of passenger transfers, station design,
and system operation.
In summary, a number of unresolved issues were felt to need
examination before finalizing the location and design of
Stage 1 facilities in the Government Center area and accept-
ing the mentioned line Section 4 study by the County's Office
of Transportation Administration (OTA).
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1
METHODOLOGY
tegitning with the basic premise that given the current
Stage 1/DPM plans, the question of interface between Stage
i and Stage 2 rapid transit lines is of critical importance.
The current Stage 1/DPM plans are shown in Figure 2 on the
following page.
The methodology employed in this study was to develop all
reasonable alternatives and to describe their potential
impacts. The review process began with a set of concept
type scenarios, each depicting generalized approaches to
the problem and briefly discussing impacts on land use,
design, operations, and the like.
A two-step screening process was developed to evaluate the
alternatives. The first step began with a review of the
scenarios. They were refined into a set of nine "centerline"
plans, using a variety of rail engineering design standards.
A set of evaluation criteria was developed to evaluate alter-
natives. The criteria were weighted by professionals in
various disciplines. The application of the evaluation cri-
teria to the nine alternatives concluded the first level
screening.
The second level screening began with the four alternatives
which were reduced to a set of four different design approaches,
each of which is described in detail. The approaches were
then tested against the original evaluation criteria. The
application of the criteria to the four design approaches
constitutes the second level screening and the completion
of this study.
All of the scenarios reviewed had the following evaluation
criteria applied as the basis for determining their impacts.
The results are reported as the basis for recommending the
most advantageous plan. The evaluation criteria are:
1 Land Use Impacts
2 Stage 1 Profile Impacts
3 Stage 2 Profile Impacts
4 Government Center Station Design
5 Washington Heights Station Design
6 DPM Interface
7 Passenger Transfers
8 Future Rail Operations
9 Equipment Movements
10 FEC Railroad Impacts
11 Costs
To initiate the study and begin the analysis process out-
lined in 2.0, the staff developed four scenarios intended
FIGURE 2
CIAtIaNT ALIGNMENT OF THE STAGE 1 RAPID TRANSIT
,MSTEM4 ANt) THE DOWNTOWN PEOPLE HOVER
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to stimulate discussion and resolution of the various issues
teisted to rapid transit facilities in the Government Center
Atea. 0f primary importance was future rail line interface
Uith Stage 1 and long-range operations considerations. Other
issues such as impacts on land use, potential problems of
vertical and horizontal alignment,
interface with the Downtown
People Mover, rider transfer connections, rail equipment move -
tent, and the like were also raised in comments on each
scenario.
The purpose of the scenarios was not to atemptdfifsy
stem
solutions, but rather to identify basic principles
location, design, and operations that needed to be addressed
before further decisions were made on precise engineering
and architectural det 11 of Stage 1 so it could accommodate
nt
future rail extensions. The scenarios were a beginning p
oi
for the establishment of basic principles to govern final
system design in the Government Center area.
2.1 Scenario 1
The original alignments and station locations were pre-
sented in the Preliminary Engineering Report of Kaiser
Engineers' "Milestone 8, Final System Design,"(MaY, 1975).
Modifications to the original Preliminary Engineering
discussed in Section 1.0 required terminating the east -
west line at the Government Center station. With the
addition of the DPM, this scenario provided the basis
for all subsequent design studies of this area, most
recently detailed in the"Final Report, Definitive Engin-
eering Study of Line Section 4 Transit Facilities,"
Kaiser Transit Group, (April, 1978).
2.2 Scenario 2
In this concept,the future northeast rail line and the
east -west line connect,paralleling the Stage 1 north -
south line, and following the FEC right-of-way to become
the proposed Stage 2 line. A station location is shown
about 11 blocks west of the proposed Stage 1 Government
Center station, although the station platform siting is
flexible within certain constraints.
2.3 Scenario 3
This is similar to 2, but locates a station just north
of the proposed Stage 1 Government Center station para-
llel to the Stage 1 Government Center station and could
allow for a single station to accommodate both rail lines.
2.4 Scenario 4
This shows the east -west line joining Stage 1 trackage and
right-of-way north of the proposed Government Center sta-
tion, and departing north of the Washington Heights station
to become the proposed northeast line.
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t'N TTAL SCREENING: THE REFINEMENT OF ALTERNATIVES
tkathination of the original alternatives and their options
gave rise to three basic issues which needed further clari-
fication. These include: (1) Ridership levels and transfer
problems; (2) Service connections between the rapid transit
lines; and (3) Stage 2 physical impacts on the Government
Center, adjacent parts of the CBD, and the Washington Heights
station. These issues are detailed below as follows:
3.1 Ridership and Transfers
The proposed year 2000 rail transit system will have
over 300,000 daily riders. During the morning rush-
hour nearly 40Z of all riders will get on and off the
system before it gets to the CBD, 35% will have CBD
destinations, 12 will transfer from one line to another,
and the balance will start their trips from the CBD.
Of the over 100,000 users getting off rapid transit lines
in the CBD, 30% will stay in the Government Center area,
5% in the Washington Heights area, and the balance will
go to other parts ofve
the
system andthelargenumber•This eores h
im-
portance of the people
of people it will have to move.
In addition, the number of system transfersbetween
lines is not overly large. The largest group
will
want to go from the east -west line to the northeast
line (5.); next is movements from the Stage 1 south
line to the Stage 1 Hialeah line (4.5%); and the third
is from the east -west line to Stage 1 south line. Other
smaller transfer movements are anticipated. The two
largest interline movements follow the basic operations
concept developed for system planning, so riders actually
do not have to get off the trains. Only 15-20,000 per-
sons daily would switch trains, which is a relatively
small rush hour volume of people. Therefore, addition-
al interline service connections and special additional
transfer stations do not appear to be necessary based
upon ridership. However, the impact on transfer move-
ments and rider access to the rest of the CBD became
significant elements for transfer analysis.
3.2 Service Connections
With a large yard and shop facility being built in the
unincorporated area adjacent to Hialeah as part of Stage
1, the need to phase in several future transit lines and
the necessity to accommodate interline rail movements,
the question of service connections is a serious concern.
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII i u■ I■II.
it equipment alone could be moved from Stage 1 lines
Mite) future extensions, future yard costs could be re,
diced and new lines phased in more easily than operating
independent lines each with their own yards and shops.
Attempts to see how various alternatives could accommo-
date primarily a non-revenue"
service connection, and
secondly an interline service connection were initiated
as part of the alternative analysis.
,3 Land Use Impacts
While it is presumed that the Stage 2 line would be
accommodated within the Government Center, the position
of the platform, the impact of the Stage 2 line on
Lummus Park, the areas east of the FEC railroad,and im-
pacts of varying levels in the Washington Heights area
all became vital issues requiring further analysis.
Opportunities to allow private development near the
Stage 2 station, bring riders closer to the CBD core,
and minimize land acquisition or displacement to residen-
tial areas, all required further analysis as well.
3.4 The Detailed Alternatives
After review by various agencies, refinements to the
four original alternative concepts were produced by
staff. These so-called "centerline" alternatives gave
more careful attention to engineering details as well
as architectural, land use, and operational elements.
The nine alternatives fall into four basic groups.
Three of the four groups were first covered in the ori-
ginal scenarios. The fourth is a resurrection of the
original preliminary engineering scheme whereby direct
rail service is carried toward Biscayne Boulevard and
other parts of the downtown area. The four basic groups
are:
.1 Stub -End Service at Government Center
A future east -west line would stub -end at the Stage
1 Government Center station, and a northeast line
would stub -end at the Washington Heights or Govern-
ment Center station.
.2 East-West/Northeast Line Connection via Government
Center
Five different design concepts were developed which
would allow a single, through service rail line to
connect east -west and northeast lines into a single
rail line. The placement of the Government Center
platform on this line, its impact on the Stage 1
line and impacts to the Government Center or areas
just east of the CBD differ among the five alignments.
•
_tistimWeet/Northeast title Connected Via Washington
'Heights
An east west line would follow a N.W. 7th Street
alignment into a refined Stage 1 Washington Heights
alignment, with service continuing into a northeast
line.
txtended East-West/Northeast Line Connection
Two alternatives propose to carry the east -west line
through Government Center eastward to the Biscayne
$oulevard corridor, then northward to make a north-
east line connection and/or loop back to the west
to tie into the Hialeah portion of Stage 1. Each of
these alternatives assumes the preliminary engin-
eering alignment of the east -west line crossing
of I-95 from the west.
Figure 3 on the following page is a matrix which
summarizes the impacts of these alternatives.
The specific alignments of the nine alternatives
are shown in Figures 4 through 12 on the following
pages. •
i
FIGURE 3
THE FOUR RASTC ALTERNATIVES
111111111111
Scenario 1
Scenario 2
Scenario 3'
Scenario 4.
Land Use Impact
Minimum
Require additional ROW for
curve west or east of Govern-
ment Center.
Curve could require addi-
tional ROW within Govern-
ment (:enter. -_.
Curve would require additional'
ROW within Government Center
Stage 1 Profile
No change
Possible shifting of horizon-
tat profile to accommodate
Stage 2 tracks.
Government Center station
relocated further north.
Possible shifting of hori-
zontal profile to accommo-
date Stage 2 tracks.
No vertical or horizontal
problems.
Stage 2 Profile
Possible vertical
profile problem
Station platform of EW line
location affect vertical
profile, curve passes
through Government Center
complex.
Stage 2 profile dependent
on I-95 and passage beneath
Stage 1.
No vertical or horizontal:
problems.
2.
Government Center Station
2 level platforms.
Major transfer point.
Station platforms would be
separated or "L" shaped.
Stage 1 platform moved
Slightly northward.
Station located further to
the north. 2 parallel
platforms required.
This station could be defer-
red to Stage 2.
No direct access to Stage
Transfer to Washington- Heights
required.
Washington Heights
Station
No impact
Provision of Stage 2 tracks
at this station. Possible
transfer point. This
station could he deferred
to Stage 2.
Relocation of Government
Center station could elimi-
nate need for this station.
Would have to accommodate
4 tracks.
Primary transfer station
between Stages 1 and 2.
Stage 2 transfer to Government
Center.
DPM Interface
No problem
Stage 2 platform would
not he directly served by
DPM without some walking
distance.
Government Center DPM stop
moved further north, possibly
combining the 2 proposed
stops.
DPM would have to be extended
to Washington Heights to
directly serve Stage 2.
Transfers
Concentrated at
Government Center.
No through EW to WE
connection.
A short walk would be re-
quired for Stage 1 and
Stage 2 transfers at the
Government Center. Through
EW to NE movement possible.
All transfers at Government
Center or Washington Heights.
Through EW to NE movement
possible.
Washington Heights the only
transfer point. Must be
des! d for transfer load.
Stage 2 Operations
g p
No through NE to EW
service. No NE
provision. EW trains
reverse a[ Government
Center.
No service connection
provided.
Uninterrupted EW to NE
Line connection without
interference with Stage 1e
The fe connection could
be deferred depending on
phasing.
Service connection would
be provided at Washington
Heights.
Uninterrupted EW to NE
line connection without
interference with Stage 1.
NE connection could
be deferred depending on
phasing.
Service connection would
he provided at Washington
Heights.
All [ripe to Government
Center must transfer.
Swtcching required on shared
trackage. Headway problems
would occur.
Service connection on shared
trackage.
RailvEquipment
Movement
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FIGURE 4
ALTERNATIVE 1
EAST -WEST LINE STUB -END:
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FIGURE 5
ALTERNATIVE 7
EAST —WEST LINE AT RIGHT ANFLF_-
SEPARATED PLATFORMS
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FIGURE 6
ALTERNATIVE 2A
EAST -WEST LINE AT RIGHT ANGLE:
CONNECTED PLATFORMS
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FIGURE 7
ALTERNATIVE 3
EAST -WEST LINE AT ANGLE SW TO NE
SEPARATED PLATFORMS
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FIGURE 8
ALTERNATIVE 3A
EAST -WEST LINE AT ANGLE SW TONF
CONNECTED PLATFORMS
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FIGURE 9
ALTERNATIVE 4
EAST -WEST LINE TURNING, IN GOVERNMENT CENTER
PARALLEL PLATFORMS
U*-4
Up
SISCAYNE eouItvARo
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FIGURE 10
ALTERNATIVE 5
EAST -WEST LINE OUTSIDE GOVERNMENT
1
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ALTERNATIVE 6
EAST -WEST LINF THROUCH CRD
NORTHEAST CONNECTION VIA NE 2 AVE
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FIGURE 12
ALTERNATIVE 7
EAST -WEST LINE THROUGH C-RD`
NORTHEAST CONNECTION VIA WASHINGTONHEIGHT'S
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•
17
4i VAPPLICATION OF EVALUATION CRITERIA
In order to provide a basis for judging the relative merits
of each of the alternatives chosen for detailed study, staff
prepared a set of evaluation criteria against which each
alternative could be measured. The criteria began with a
statement of the problem and the goal being sought, and follow-
ed with a set of objectives to be achieved in design and opera
ation of Stage 1, particularly in the Government Center area.
Following is the statement of objectives which comprise the
evaluation criteria.
4.1 Ridership
To provide efficient and convenient movement of pass-
engers throughout the transit system.
. 1 Passenger travel on the rapid transit system to
both the Government Center and downtown destination
(particularly as this travel relates to the DPN)
should be efficient and convenient.
. 2 Rapid transit stations should be located and
designed to minimize passenger inconvenience and
total travel time to these destinations.
. 3 Stage 1 and future transit lines should be con-
figured so as to minimize transfer movements.
.4 Walking distances between transfer points should,
be minimized.
.5 Where practical, more than one transfer location.
between rail lines should be provided.
4.2 System Operations and Service Connections
Rapid transit design and configuration should provide
for reliable, efficient, and flexible system operation.
. 1 Non -revenue service connections between all lines
should be provided to allow efficient and balanced
operations and maintenance.
. 2 Where practical, line extensions should be connected
with each other to allow through train movements,
reducing possible turnaround activity in the Govern-
ment Center area.
. 3 Design standards should be adhered to while taking
into account line -segment and/or site -specific
characteristics.
11111111111111111111 11111111111111111111111111111111111
18
t4 be -Sigh for future extensions should allow fot the
possibility that any or all proposed lines may not
be built, and that future extensions may be subject
to changes in proposed alignments.
tapid transit design and configuration should harmonize
With existing and planned land uses in the Government
Center and adjacent areas to the fullest extent possible.
.1 Disruptive land acquisition should be avoided, such
as public amenities (parks, historic sites, etc.)
expensive structures, or acquisition requiring re-
location of residents and/or businesses.
. 2 Rapid transit design and configuration must not
adversely impact existing or committed components
of the Government Center plan.
. 3 Adverse visual and noise impact associated with
transit design should be minimized.
. 4 Encroachment of the system into adjacent parts of
CBD and residential areas should be minimized.
.5 Washington Heights station location should be
acceptible to the community and harmonize with
CBD development programs.
Following further discussion and evaluation of the nine
alternatives, four concepts were chosen for detailed
study.
These criteria form the basis for the first level of
screening of alternatives. The screening process amounted
to a detailed application of one criterion to each alter-
native, weighting ridership at 50%, operations at 35%,
and land use at 15%. The application of these criteria
to the nine alternatives is shown in Figure 13 on the
following page. Essentially, Figure 13 demonstrates the
primary reasons for the selection of the four alternatives
identified for final evaluation. Alternative 1 was selected
because it is the base alternative; that which presently
exists. Alternative 3A was selected because it permits
a continuous east -west to northeast connection, and
interfaces well with Stage 1 and the DPM. Alternative
5 was selected because its impact on Government Center
would be minimal. Alternative 6 was selected because it
permits a continuous east -west to northeast connection
through the Miami CBD, complementing the DPM.
II
II
1
III
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11
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IIIII
IIII
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11 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIII IIIIIIII II I IN miiiiiiimmumumi
assommorn
111111, ill11111I1111911„
FIGURE 13
SUMMARY OF IMPACTS ON THE GOVERNMENT CENTER
Alternative
2
Direct
Dlatfo
Platform
Connection
Possible
EW-NE 2
NE
Ehrou
Through
Service
Possible
without
Transfers
Stage 2
Service
Connection
to Stage 1
Possible
Stagee2
Revenue
Connection
to Stage 1
Possible
flcatMajor Mns
flcatione
to Stage 1
Line Required
to Accommodate
Stage 2 Line
No
No
No
No
No
Yes
_.. -
No., -
Na
Stage 2
R
Impact on
Government
Center
Minimal
Minimal
Minimal
Modest
Minimal
Modest
Minimal
Minimal
Minimal
Future Extensions
Impact on other
Adiacent Areas
A Land Use Plan
Stage 2'
AccommodatEo�r
of Transfers
Stage z
Accommod"at`kion'.p
of CeDtRfd'era--
Substantial2
Substantial
Substantial
Minimal
Substantial
Minimal
Substantial
Very Substantial
Very Substantial
Poor
Fair
Good
Fair
Good!
Good
Poor
Good
Goof
Goods
Poor
Good
Poor
Good
Fair
Very Poor
Very Good
Very Good
14
2
2A
3
3A4
4
54
64
7
Yes
No
Yes
No
Yes
Yee
Yes
Yee
Yes
No
No
Yes
No
Yes
Yea
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yesl
1
Yea
1
Yes
Yes
1,Yes
Yes
1
Yes
No
Yes
III
II
Would require more detailed analysis to determine feasibility.
Anticipates 1000' tail track (standard system requirement
3 Assumes completion of DPM system.
1 Selected for final analysis.
II
91
II
Ili
for overshoot)
I
A
I
A
A
iIIMaiii iii$iiiiiiiiiiiiii 111
iu
i
20
LEVER NO SCREENING OF DESIGN APPROACHES
1 Alternative Design No. 1
This alternative is based on the stubs -end tettitiatioii
of the east -west and northeast Stage 2 rail line at
the Government Center. There is no connection between
the east -west and northeast line or the east -west with
the Stage 1 rail line. A service connection is provided
between the northeast line and the Stage 1 line.
The east -west line follows the Preliminary Engineering
alignment into the Government Center, but terminates
at a right angle to the Stage 1 Government Center station
platform and at the same elevation as the Stage 1 platform.
There is no provision for a tail track. Trains would be
reversed in the station and return via crossover tracks.
Elevation of the top of the rail at this station is 59 feet.
The gradient over 1-95 is 3.0% and all curves are within a
1,000' radius.
The northeast line enters the study area via the FEC
rail line running immediately adjacent and parallel to
the Stage 1 alignment from Washington Heights terminating
at the Government Center. A service connection is pro-
vided at Washington Heights. The Government Center
platform is staggered approximately 100' north of the
Stage 1 platform at the same 59' elevation, requiring
a 3.n grade to reach the platform at which point the
line is terminated with no tail track. Reverse move-
ments are made via crossovers north of the platform.
There are no curves required for this portion of the north-
east line.
This alternative requires an extended platform for the
east -west line through the Government Center, provisions
in the Stage 1 Government Center station for extended
mezzanines and platforms, and provisions in the Washing-
ton Heights station for a service connection crossover
and adjacent parallel tracks. This plan does not pro-
vide through east -west to northeast revenue or non -revenue
operation nor does it allow a service connection for the
east -west line to Stage 1. The system would be operated
as three separate lines, two terminating at the Govern-
ment Center. All transfers between Stage 1, the east -
west line, and the northeast line would necessarily take
place at the Government Center station.
5.2 Alternative Design No. 2
This alternative provides a through connection of the
east -west line with the northeast line via Downtown
Miami, with transfers between Stage 1 and Stage 2 occurring
at the Government Center station.
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THE KAISER TRANSIT GROUP 'Joint venture
KAISER ENGINEERS POST SUCKLE SC wUw AJ[R/RCdK NC -
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ALTERNATIVE DESIGN 2
EAST -WEST LINE AT RIGHT ANGLE
IN GOVERNMENT CENTER
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 2
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this alternative follows the PE alignment from the
Vest, crossing 1-95 and passing through the Government
Center at a 3% downgrade to an elevation of 39 feet,
at which point it levels off at the Government Center
station. This station platform is at a right angle to
the Stage 1 platform forming a "T" shaped station. East
of Stage 1, the Stage 2 alignment follows Second Street
east several blocks and then turns north within the Bis-
cayne Boulevard corridor to become the northeast line.
All grades are within the 3.0% standard. There are no curves
within the Government Center; however, a turn would be
required within the downtown to the northeast. Dis-
ruption in the Government Center is minimal. However,
passage directly through the downtown would require
special treatment to streets and some land area. While
providing a direct east -west to northeast connection
and direct downtown accessibility, this plan does not
provide a service connection between Stage 1 and Stage 2
and would require careful consideration of downtown impact,
particularly with respect to the proposed Downtown People
Mover system.
5.3 Alternative Design No. 3
This alternative provides a through connection of the
east -west line with the northeast line. Stage 2 inter-
sects Stage 1 at an angle at the Government Center station
with a curve located west of Miami Avenue. A service
connection is provided between Stage 1 and Stage 2 lines.
The east -west line follows the PE alignment into the
Government Center following a slight southeastward
alignment before curving to a northeastward alignment
with a 750' radius curve. Between I-95 and immediately
west of Stage 1 this line descends at a 3.0% grade to an
elevation of 39.0 feet, at which point the Stage 2 Govern-
ment Center station platform is situated at an angle be-
neath the north end of the Stage 1 platform. A slight
0.3% downgrade is retained through this station. The
Stage 2 platform is located primarily east of the Govern-
ment Center boundary extending to the northeast across
N.W. 1st Avenue and N.W. 3rd Street. The line then curves
through four blocks of low rise or vacant commercial devel-
opment, extending as far east as the immediate east side
of North Miami Avenue. At this point, it turns northwest
over the FEC Dodge Island spur to enter the main FEC
right-of-way immediately north of the Stage 1 Washington
Heights station. A service connection located on the
curve at Washington Heights would be made between the
Stage 1 and Stage 2 lines. The Stage 2 line continues
north leaving Stage 1 right-of-way passing beneath the
East/West Expressway and the northeast in the FEC right-
of-way.
Egg
1
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+80
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105 115
e,'. LAPPPOxIMATE EXISTING GPOUN
FIGURE 161125
ALTERNATIVE DESIGN 3
EAST -WEST LINE AT ANGLE SW TO NE
IN GOVERNmENT CENTER
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 3
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GOVERNMENT CENTER STAT/ON
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1.
NE.CORRIDOR STATION
105
ansportation Improvement Program
■
■
THE KAISER TRANSIT GROUP • pint venture
RAISER EN,dkf EPS
OV.ISRM LA W •P.. Iu su. cow,.
HARR', NE ESE 4 ASSOCIATES co
POST BUCRLET SCHUH A JERNIGAN. NG-
CARP SMITH WO A55CCIAT ES INC
SCHINPELEII COPRADINO ASSOCIATES
d
N.4 COF tIoo _
115 FIGURE 161125
ALTERNATIVE DESIGN 3
EAST -WEST LINE AT ANGLE SW TO NE
IN GOVERNMENT CENTER
+120
+BO
+ 40
-40
1,14CA II
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 3
KAII•40'• VERT
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25
the gtage 2 alignment between 1-95 and the East/West
tkpressway requires 3 curves separated by tangents,
ttio of which (on each side of the Government Center
platform) have a 750'radius; the third has a 1,000'
radius. All grades are within the 3.0% standard.
The service connection requires a crossover on a curve:
however, the direction of normal revenue operation is
"with" rather than "against" turnout points, reducing
any potential safety hazard. This plan requires acqui-
sition of right-of-way between N.W. 1st Avenue and North
Miami Avenue and N.W. 3rd Street and N.W. 8th Street.
A curved alignment is required through the Government
Center, but the Stage 2 platform will lie primarily
outside the Government Center with street access in
addition to access from the Government Center.
This alternative provides an east -west to northeast
revenue connection and a Stage 1 to Stage 2 service
connection. It does not provide for direct Stage 2
access to the Washington Heights station and all Stage
1 to Stage 2 transfers would necessarily take place at
the Government Center station. Land impact on the
Government Center is minimal, but right-of-way would
have to be taken east of Stage 1. The Stage 2 alignment
could affect DPM routes through this area.
5.4 Alternative Design No. 4
This alternative represents a departure from the others
in that it assumes an alignment for the east -west line
along N.W. 7th Street and intersects Stage 1 at Washington
Heights rather than the Government Center. It provides
a through east -west to northeast line connection, but
does not include a service connection between Stage 1
and Stage 2 (although one could be accommodated). There
is no direct Stage 2 connection with the Government Center.
The east -west line crosses I-95 from N.W. 7th Street on
a 3.0% grade west of 1-95 and a 1.0% grade east of 1-95
at which point it remains at an elevation of 59', curv-
ing northeast to pass over Stage 1 at Washington Heights.
At this point of intersection the Washington Heights sta-
tion forms an "x" arrangement requiring right-of-way
acquisition around both platforms. This station is the
only Stage 1 to Stage 2 transfer point. The Stage 2
alignment joins the FEC northeast right-of-way at N.W.
llth Street passing below the East/West Expressway
forming the northeast line.
This alternative has no impact on the Government Center
with respect to future rail extensions. The Washington
Heights station becomes a major transfer location. It is
important to note that this plan requires a relocation
of the Washington Heights station and is not feasible if
the station remains in the approved Stage 1 alignment.
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•ansportation Improvement Program
FIGURE 17
ALTERNATIVE DESIGN 4
EA ' MES1 L11( OUTSIDE GOVERNMENT CENTER
+ 120
+ 80
+ 40
0
— 40
THE KAISER TRANSIT GROUP .punt venture
KAISER ENGINEERS
DoRAKIN Co W NN, J ausem COWPDX,
HARRY WEESE A ASSOCIATES LTD
POST BUrKLET SCHUNA JERNIGAN. INC
CARR SMITH AND ASSOCIATES. NC
SCINANI LER CORRAOXNO ASSOCIATES
aHNl0.1 °
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 4
scut Ia•40'• VEFT
°"""" S K C —191
.ti
IBmwo
flA
which
27
'Whit this plan elihinates the need fot ptovision of
future facilities at the Government Centeti it does
requite the relocation of the Washington Heights
Station and provision for the Stage 2 platform and
right-of-way. All Stage 2 riders destined for the
Government Center or the Miami CBD would be required
to transfer to Stage 1 trains to get to the Government
Center station.
5,5 Analysis of Final Alternative Designs
The four final design alternatives developed have had
their various features summarized in Figure 18 to facil-
itate comparison. Figure 18 is a matrix highlighting
the different impacts of each alternative, and thus
summarizes detailed analysis of the different schemes.
The alternatives were evaluated against the criteria
listed in Section 4.0 of this report. Based upon the
criteria, the four alternative designs fell into two
categories: Acceptable and Unacceptable. A discussion of
these rankings is as follows.
.1 Unacceptable Alternative Designs
Based upon the criteria discussed earlier in this
report, design concepts No. 1 and No. 4 have major
deficiencies which make them unacceptable design
alternatives for future planning. Their shortcomings
result in their elimination from further con-
sideration are as follows:
Alternative Design No. 1
Summary of deficiencies
IIIK
• Poor rail operating conditions
• Inadequate rail passenger transfer conditions mmmim
• Lack of service connection
• Substantial land use impacts in the Govern -
went Center itself to accommodate additional
platforms
Cost: $29.350 million
The very poor transit operations environment and
passenger accommodations created by placing two or
three stub -ended lines in the Government Center, makes
this design concept undesirable. Storage and cross-
over space in the Government Center would be needed to
make stub -ended configurations work. A relatively high
price would be required for this concept.
28
Alt .native_ Design No. _4.
Stith -Mary of deficiencies
• Poor service connections
• Inconvenient passenger tnovetnetts
• Substantial land use impacts in Washington
Heights area counter to approved Stage 1 plans
• No DPM interface
Cost: $13.750 million
The major disruption this concept causes in the
Washington Heights area is counter to approved neigh-
borhood plans and citizens' desires. While this is the
least expensive scheme, it would cause many addition-
al passenger transfers as riders try to get to the
Government Center from the east -west lines. Finally,
the lack of interface with the DPM system is contrary
to public policies.
. 2 Acceptable Alternative Designs
Both alternatives No. 2 and No. 3 were judged to be
acceptable for future planning purposes even though
they are substantially different from each other.
Both schemes avoid operational problems, unacceptable
land use, or ridership problems encountered in the
other two alternatives previously discussed. However,
alternatives No. 2 and No. 3 have both positive and
negative facets which need to be brought forward and
analyzed.
Alternative Design No. 2
• Rail operating conditions are good
• Rail service connections are poor
• Optimal transit rider accommodations and
travel time savings
• Very substantial land use impacts in the CBD
• Conflicts with DPM policies
Cost: $31.775 million
This concept, which is similar to many early pre-
liminary engineering proposals, runs the east -west
line across the CBD around 3rd Street. While this
provides the highest level of transit rider service,
it also produces the highest level of land use impacts
(including disruption to Southern Bell operations),
will have negative impacts on DPM usage, and would be
the most difficult and costly to build.
29
Rite nAt_i_Ve besign F2o._ 3
i tail operating conditions are good
i Only alternative providing a service
connection
i Good rider transfer and destination
accommodations
i Substantial land use impacts east of the
Government Center
i Good DPM interface.
Cost: $20.750 million
This concept has the rail operating characteristics
of through line service, and allows inter -line
service connections, DPM interface, and good rider
movements between lines and to their final destina-
tion. There will be major land use impacts just east
of the Government Center. There is also the possi-
bility of modifying the northern line to parallel
Miami Avenue into the Buena Victa yardo and realign-
ment of the line section through the Government
Center adjacent to N.W. 2nd Street. The cost is the
second lowest of the four design alternatives.
i
1111111111
1
I
I
IIII IIII
111111
■1
Alternative D►Rign t
Line Characteristics
Fir:IMF 1R
r'w frog AtTFRNATIVF. IFSTC.NS
SIReOIRY nF CItARA rFRISTTCS
Three line*: 1. Ntaieuh-
Dadeland. 2. Little Nevins -
Cnvernment Center. 3. north-
east Dade-Govern*ent Center.
Alternative Design 2
Tan lines: 1. Nlaieah-Dsde-
land. 2. Little Havana-Nnrth-
east Dade via Miami CND.
Alternative Denlen 1 Alternative Denten, ti•
Tvo linen: 1. H1uleah-Dade-
1and. 2. Little Navnnn-
Nnrthenet Dade.
Tto lines: 1. Hialeah -
Dadeland. 2. Little- Novena.
Nnrthenat Dade vt* Wnnhing-
ton Height'.
Station Configuration
Government Center: two
parallel pintfnrmn and a
third at right angle to
went, all at *arm (59') el-
evation. Washington Weight's'
two parallel platform' at
same (37') elevation.
Government Center: Line 2
p under Line 1 at
right angle. Washington
Heights: 'tame nn Stnge 1.
Government Center: Line 2
C order nnrth end of
Line 1 platform at angle
of spprnrtantely 6S".
WnahingtonHeights: name
aN Stage 1.
Government Center: Not
affected. Washington Hdabt_:
Line 2 p'tnn.A over north end,
of Line 1 platformnt rouRhlp
rtaht angle.
Operational Characteristics
a. Tail tracks
b. Service Connection*
C. DRt interface
Line 1: N/A. Line 2: none
Line 3: none.
Line 1 to Line 2: no. Line 2
to Line l: no. Line 3 to
Line 1: yew.
Difficult
tas..nter SertiST
a. cnnlcnvernmmt Center
destination
b. Clete Center destination
t. Little Novena -
Northeest Dade Service
Line 1 from north L south:
good. Line 2:gnod. Linn 3:
good.
Line 1 from north 1; south:
good. Line 2:trenefer re-
lated. Line 3: transfer re-
quired.
Transfer required
Line 1: N/A. Line 2: N/A
No
Good
Line 1 from north I. Routh:
good. Line 2 from east i
meat: good.
Line 1 from north i Routh:
Rood. Line 2 from east 6
rest: transfer required.
Through service
Line 1: N/A. Line 2: N/A
Tea
Good
Line 1 from north A south:
gond. Line 2 from emit 6
west: good
Line 1 from north 6 Routh:
good. Line 2 from emit 6
went: transfer required.
Through service
Line 1: N/A. tine 2: RIM
No
No
Line 1 from north & .outfit
good. Line 2 from -*mat S.
meat: transfer required'.
Line t tram north i mouth:
good. Line 2 from egret S-
weat: transfer required`.
through Nervtre
Land Use topic[
a. Within Government Center
b. Adjoining green
M1nimm1
Minimal
Mfntmml
Very mubRtsnttal
Minimal
SnhRtantial
Cetimeted Cost (1976 dolllre)
S29.350,000
Comments
Government Center mtetinn
is cnmpltceted. Lick of tail
trarkn not rofNi@stent with
oyster, @safety specifics -
flows. No ',termite rnnnectlon
between l.tn• 2 and rent of
.,)stem. Stage 2 ennetruc-
tlnn disruptive to Stage 1
operation*.
S31.215.000
No service connection
between lines.
Provtdea additional
downtown nervtre.
S20.250,000
Only mlternattve providing
nervtre connection. Require'
additional right-of-way en+t
of Government Center.
None
Substantial!
ST1150-.000
Require* relecnttntr off
Wnehtngtnn ileightw
'tatton from approved'
location on Stage 1.
IAA
0
31
tit) tONCLtSIbNS
While none of the alternative design concepts offer an
ideal situation, the immediate differences between the un=
acceptability of alternatives No. 1 and No. 4, vs. accept-
able designs No. 2 and No. 3 are evident from land use, set=
vice, and ridership viewpoints. Thus the rationale behind
the initial rejection of alternatives No. 1 and No. 4 is
clear.
The differences between No. 2 and No. 3 are in many ways
also decisive. Alternative No. 3 is less disruptive, both
within the Government Center and in the CBD;is less costly,
has better coordination with and does not compete with the
DPM, and allows inter -line service connections and good transit
rider accommodations. Alternative No. 2 suffers by compar-
ison on these issues and is therefore less satisfactory.
Alternative No. 2 has a singular advantage in its ability
to carry transit riders directly into the heart of the CBD
and allow possible private redevelopment adjacent to the
right-of-way. While this is desirable,based on ridership
demands and the heavy loads that the DPM might be burdened
a witlt,Alternative No. 2 represents a major departure from
MEE currently adopted policy, is far more expensive, and has
operational drawbacks which negate its ridership advantages.
Therefore Alternative No. 3 and its possible modification
represents the clearest choice for future Stage 1/Stage 2
interface at this time. Future investigation could modify
Alternative No. 3 into a scheme that offers better CBD pen-
etration or replaces the DPM in certain areas dependent
upon the final design concepts advanced for the DPM and CBD
development schemes. The flexibility of Alternative No. 3
is therefore unique in that no other alternative design
could allow as much future modification potential. The choice
of Alternative No. 3,with slight profile and alignment changes
to make it fit into the Government Center as easily as possible,
appears by all evaluation standards to be the optimal choice
for future planning efforts.
•
■
0
A STUDY OF TRANSIT ALTERNATIVE ALIGNMENTS
AND THEIR IMPACT ON THE
GOVERNMENT CENTER AREA
OFFICE OF TRANSPORTATION ADMINISTRATION
August 14, 1978
J
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78-657.
`N.
To:
•
ruoM: Joseph R: Grassie.
• City Manager
Mayor and Members
City Commission
CITY OF MIAMI. :"'..''RtoA
!.'ltER-07FIC7. MEMORANDUM
DAY'OCT 20 197
orfrEttUtCr3:
Attached for your review is a recent Dade County report entitled
"A Study of Transit Alternative Alignments and their Impacts on
the Government Center Area".
The proposed east -west phase II of the Rapid Transit System will
cross the presently designed phase I alignment at the Government
Center Station. Th.2 design of the Governre nt Center Station that
is now underway must incorporate the best alternative crossing.
A presentation to the Commission on these alternatives will be made
by Dade County at the October 24th Commission meeting. The county
report favors alternative No. 3 which has a diagonal alignment
through the Government Center and a connection east of the Government
Center to the FEC railroad for the route north to 163rd Street.
It should be noted that Mr. Geddes October 17th report to the County
Commission on the master plan for the Government Center recommended
a straight Phase II crossing of the Government Center along NW
2nd Street which implies that alternative No. 2 may be the most
compatible with the objectives of the Government Center plan.
■•
1
-+1 ' eo ► N'"'N "'� '7 nay a . ? Z = ! y -+ti 0.M r DA
911 COURTHOUSE
MIAMI, FLORIDA 33130
TEL: 579-5311
OEEiCE OF COUNT`` MANAGER
tinhard Fosmoen
Assistant City Manager
City of Miami Planning Department
3500 Pan American Drive
Miami, Florida 33131
Dear Mr, Fosmoen:
SEP 2 8 1278
Attached for your review and comment is a recently completed report
entitled "A Study of Transit Alternative Alignments and their Impact on
the Government Center Area". This report was needed to facilitate un-
interrupted progress in the design of the Government Center complex.
Since the design of the remaining buildings in the Government Center
complex is underway, space allocations for all transit related facili-
ties must be made as quickly as possible. Therefore, this report was
designed to promote suggested alternatives and elicit comments from
interested groups.
The report recommends that alternative alignment concept No. 3 be
adopted for future planning. This alternative causes the least disruption
through the Miami CBD, and also provides a service connection between the
Stage 1 rapid transit system and future rail extensions. This makes a
second multi -million dollar maintenance yard and shop site unnecessary,
and would reduce future costs and speed-up development of new extensions.
It also provides for transfers among Stage 1, future rail extensions,
and the DPM system at one central location.
If you have any comments with regard to this report, please contact
Fred Silverman at 579-5672 or myself.
ncerely.
1f
John A. Dy
Transport. ion Coordinator
Ca,•
C,
!.7
CITY OF `t1AMI.
iN i t R-:iFFIC:= ;�iE",10i2 a �1D1�P11
TO: Mayor and Members of the -,iz�. OCT 0 1978
City Commission
S :,l,ttJECT
i
1 ; vc...t. Joseph R. Grassie "` rtf1.1 EFIENCt:i:
ICity Manager
1 1
The Planning Department, has been under contract to Dade County,
for the past several months to plan the areas around Miami's ten
transit stations, a process known as Station Area Design and de-
mm
velopment (SADD). To date planning staff have completed a de -
MO scription of existing conditions around these stations and are
MM_ publishing the findings in brief reports for each station area.
MI
Copies of the firstthree reports issued in the City of Miami for
the Douglas Road, Coconut Grove and Vizcaya Stations are attached.
The reports provide the basis for initiating the SADD citizen
participation planning program that is scheduled to begin November.
In addition these documents will provide advance information for
property owners, developers and investors who will be seeking
opportunities for development near transit stations.
The next step in the process will be public hearings before the
Commission this spring on SADD phase II during which alternative
concepts for development in transit station areas will be proposed.
This will result in a refinement of alternatives in a final recom-
mended concept plan (Phase III) in late 1979. These final phase
III plans, if adopted by the City Commission after public hearings,
would govern all public and private development actions in transit
station areas.
This three phase process is described in the Regional Profile
(also attached), which gives a system -wide overview of the SADD
program.
1
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Mt t H OD 0160 G Y 4 c 4 4 i+ 1 4 1 1 1. 4 1 4 4 1 4 4 4$ 1 4 4 4 4 4 1 1 1 t,t1 1 1 V 1 t 1 t
INITIAL SCREENING: THE REFINEMENT
OF ALTERNATIVES i i 4 i i 1 1+• 4• 4 1 1 1 i 4 i f• l l 4 4 1 1 1 1
A10
zb LEVEL TWO SCREENING OF DESIGN APPROACHES
6 b
APPLICATION OF EVALUATION CRITERIA 4/+1444411
CONCLUSIONS 4 1 1 4 4 4 4 4 4 1 4 1 4 4 4 i 8 4•• l* i 1={ i i l 4
The preparation of this report has been financed in part
through a grant from the U.S. Department of Transportation,
Urban Mass Transportation Administration, under the Urban
Mass Transportation Act of 1964, as amended. The opinions,
findings, conclusions expressed in this report are not
necessarily those of the Urban Mass Transportation
Administration.
ii
■
1
•
■
•
L1§T 0t fiGURES
Witi5W1 Go'tetntnent Centet..:............: r �. is
Current Alignment of the Stage 1 Rapid
'ttansit System and the Downtown People :covet......
The Four Basic Alternatives
. . . . . . .
4. Alternative 1 - East-West Line Stub-End......ti..
5. Alternative 2 - East-West Line at Right
Angle,Separated Platforms
6. Alternative 2A - East-West Line at Right
Angle,Connected Platforms
7. Alternative 3 - East-West Line at Angle
SW to NE, Separated Platforms
8. Alternative 3A - East-West Line at Angle
SW to NE, Connected Platforms
9. Alternative 4 - East-West Line Turning in
Government Center,Parallel Platforms
10. Alternative 5 - East-West Line Outside
Government Center
. .
11. Alternative 6 - East-West Line through CBD,
Northeast Connection Via NE 2nc; Avenue
12. Alternative 7 - East-West Line through CBD,
Northeast Connection Via Washington Heights
13. Summary of Impacts on the Government Center
14. Alternative Design 1 - East-West Line
Stub -End
-6 t
15. Alternative Design 2 - East-West Line at
Right Angle in Government Center
16. Alternative Design 3 - East-West Line at
Angle SW to NE in Government Center.........:..,
17. Alternative Design 4 - East-West Line
Outside Government Center
18. The Four Alternative Designs:
Summary of Characteristics
16'
19
MM
Perhaps the most significant long. -term public policy
decision the Board of County Commissioners will make during
the next few months is how it decides to fit its fixed guide-
way public transportation facilities with the public buildings
planned for the area generally defined as the Government
Center. The Government Center area consists of more than
33 acres located on the western boundary of the Central Bus-
iness District (CBD).
The reason for the timing of the decisions is that the fixed
guideway transit system is to be built in three or more stages
with the first stage of some 20.5 miles from Dadeland on the
south to Hialeah on the west being under final design at the
present time. Construction on the first stage is to begin
in 1979 with operations to begin in 1983. The designs of
buildingsand the first stage of the transit system are to
the point that the cross or "X" in the system must be defined
in absolute terms and the design frozen so that architects
and engineers of the building facilities and the transit sta-
tion at the Government Center can proceed to complete their
tasks on a timely basis.
The basic rail transit system as either committed or planned
for Metropolitan Dade County consists of at least three major
elements, all of which interface at or near Government Center
in the Miami CBD. These are: (1) Stage 1 -- Hialeah-Dadeland;
(2) East -west line from Little Havana to Northeast Dade; and
(3) Downtown People Mover (DPM) within the Miami CBD.
The focal point of the entire system is the Government Center,
a new complex of County, City, State, and Federal buildings
on the west side of Miami's CBD. The Stage 1 rapid transit
line runs along the east side of the complex over the Florida
East Coast Railroad (FEC) right-of-way. Several buildings
have already been completed, others are under design and still
others are in planning.
The original plan for the Government Center was completed in
1975. The 2000 Site Plan which emerged from the study in 1975
is shown in Figure 1. To avoid future design conflicts, the
1975 master plan for the Government Center is being re-examined
and brought up to date. Completion of this study is proposed
for September or October, 1978. Simultaneously, investigation
of the interface between Stage 1 of the rapid transit system
and future extensions has been initiated to allow Government
Center design decisions to accommodate these extensions and to
modify original Preliminary Engineering concepts regarding
future rapid transit service impacts within the CBD and the
FIGURE 1
bOt3N1OWN GOVERNMENT CENTER
WM
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ILLUSTRATIVE SITE PLAN
year 2000
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44
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so. w S'REr
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11110•1■1111111■ ■Iniiuiiiiiieiiiiiiiii ii
tea_
GoVernment Center. A major change is the Downtown People
Mover (DPM) and its interface with operating rapid transit
lines which was not considered during Preliminary Engineering
of the original Government Center planning.
Compounding these elements are design considerations that
require the Stage 1 transit line to accommodate the following:
(1) Adequate vertical clearance over the Miami River and I-95;
(2) Harmonious connections to the Government Center complex,
older parts of the CBD, and the DPM; (3) Adequate vertical and
horizontal spacing to allow for locating the Washington Heights
station; (4) Allowance for maintaining a viable Florida East
Coast rail operation; (5) The operation of north -south and
east -west line rail services; and (6) Passenger transfer
between lines.
This report examines the problems and issues regarding future
rail extensions and presents information concerning options
for these extensions, with varying impacts to design standards,
disruption to existing and planned land uses, and service con-
siderations, and relates them to the development of the Govern-
ment Center and adjacent areas. Finally, the report makes a
recommendation on the most advantageous alternative.
Some of the technical problems which have to be considered
are described in the Kaiser Transit Group's final report,
"Definitive Engineering Study, Line Section 4 Transit Facil-
ities," addressing the question of the Miami River crossing
of Stage 1, and its impact on the Government Center station.
Two fundamental problems result from this KTG study:
1. The lack of service connection between the Stage 1
and future lines could adversely affect system oper-
ations by precluding vehicle transfer from one line
to the other to balance operations, making it necessary
to build a second heavy -maintenance facility serving
only the east -west line (or, alternatively, hauling
vehicles "off-line" to the Hialeah yard for mainten-
ance).
Lack of revenue connection between the east -west
line and the northeast Dade line would result in a
system consisting of three lines, two of them ter-
minating at or near Government Center, exacerbating
problems of passenger transfers, station design,
and system operation.
In summary, a number of unresolved issues were felt to need
examination before finalizing the location and design of
Stage 1 facilities in the Government Center area and accept-
ing the mentioned line Section 4 study by the County's Office
of Transportation Administration (OTA).
2 METHODOLOGY
$eginning with the basic premise that given the current
Stage 1/DPM plans, the question of interface between Stage
1 and Stage 2 rapid transit lines is of critical importance,
The current Stage 1/DPM plans are shown in Figure 2 on the
following page.
The methodology employed in this study was to develop all
reasonable alternatives and to describe their potential
impacts. The review process began with a set of concept
type scenarios, each depicting generalized approaches to
the problem and briefly discussing impacts on land use,
design, operations, and the like.
A two-step screening process was developed to evaluate the
alternatives. The first step began with a review of the
scenarios. They were refined into a set of nine "centerline"
plans, using a variety of rail engineering design standards.
A set of evaluation criteria was developed to evaluate alter-
natives. The criteria were weighted by professionals in
various disciplines. The application of the evaluation cri-
teria to the nine alternatives concluded the first level
screening.
The second level screening began with the four alternatives
which were reduced to a set of four different design approaches
each of which is described in detail. The approaches were
then tested against the original evaluation criteria. The
application of the criteria to the four design approaches
constitutes the second level screening and the completion
of this study.
A11 of the scenarios reviewed had the following evaluation
criteria applied as the basis for determining their impacts.
The results are reported as the basis for recommending the
most advantageous plan. The evaluation criteria are:
1 Land Use Impacts
2 Stage 1 Profile Impacts
3 Stage 2 Profile Impacts
4 Government Center Station Design
5 Washington Heights Station Design
6 DPM Interface
7 Passenger Transfers
8 Future Rail Operations
9 Equipment Movements
10 FEC Railroad Impacts
11 Costs
To initiate the study and begin the analysis process out-
lined in 2.0, the staff developed four scenarios intended
MOs
FIGURE 2
CUArttNt MA NttEnT OF THE STAGE 1 RAPID TRANSIT
nn'tt.1 AND THE DOWNTOWN PEOPLE HOVER
tt b nit
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66.111 St •
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,:. _•;.:, st.i It. '
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1K-77
3
to stimulate discussion and resolution of the various issues
related to rapid transit facilities in the Government Center
area. Of primary importance was future rail line interface
With Stage 1 and long-range operations considerations. Other
issues such as impacts on land use, potential problems of
vertical and horizontal alignment, interface with the Downtown
People Mover, rider transfer connections, rail equipment move. -
tent, and the like were also raised in comments on each
scenario.
The purpose of the scenarios was not to attempt definitive
solutions, but rather to identify basic principles of system
location, design, and operations that needed to be addressed
before further decisions were made on precise engineering
and architectural det 11 of Stage 1 so it could accommodate
future rail extensions. The scenarios were a beginning point
for the establishment of basic principles to govern final
system design in the Government Center area.
2.1 Scenario 1
The original alignments and station locations were pre-
sented in the Preliminary Engineering Report of Kaiser
Engineers' "Milestone 8, Final System Design,"(May, 1975).
Modifications to the original Preliminary Engineering
discussed in Section 1.0 required terminating the east -
west line at the Government Center station. With the
addition of the DPM, this scenario provided the basis
for all subsequent design studies of this area, most
recently detailed in the"Final Report, Definitive Engin-
eering Study of Line Section 4 Transit Facilities,"
Kaiser Transit Group, (April, 1978).
2.2 Scenario 2
In this concept,the future northeast rail line and the
east -west line connect,paralleling the Stage 1 north -
south line, and following the FEC right-of-way to become
the proposed Stage 2 line. A station location is shown
about 11 blocks west of the proposed Stage 1 Government
Center station, although the station platform siting is
flexible within certain constraints.
2.3 Scenario 3
This is similar to 2, but locates a station just north
of the proposed Stage 1 Government Center station para-
llel to the Stage 1 Government Center station and could
allow for a single station to accommodate both rail lines.
2.4 Scenario 4
This shows the east -west line joining Stage 1 trackage and
right-of-way north of the proposed Government Center sta-
tion, and departing north of the Washington Heights station
to become the proposed northeast line.
_•
•
1:0 INITIAL SCREENING: THE REFINEMENT OF ALTERNATIVES
Ecamination of the original alternatives and their options
gave rise to three basic issues which needed further clari-
fication. These include: (1) Ridership levels and transfer
problems; (2) Service connections between the rapid transit
lines; and (3) Stage 2 physical impacts on the Government
Center, adjacent parts of the CBD, and the Washington Heights
station. These issues are detailed below as follows:
3.1 Ridership and Transfers
The proposed year 2000 rail transit system will have
over 300,000 daily riders. During the morning rush-
hour nearly 40% of all riders will get on and off the
system before it gets to the CBD, 35% will have CBD
destinations, 12% will transfer from one line to another,
and the balance will start their trips from the CBD.
Of the over 100,000 users getting off rapid transit lines
in the CBD, 30% will stay in the Government Center area,
5% in the Washington Heights area, and the balance will
go to other parts of the CBD. This underscores the im-
portance of the people mover system and the large number
of people it will have to move.
In addition, the number of system transfers between
lines is not overly large. The largest group will
want to go from the east -west line to the northeast
line (5%); next is movements from the Stage 1 south
line to the Stage 1 Hialeah line (4.5%); and the third
is from the east -west line to Stage 1 south line. Other
smaller transfer movements are anticipated. The two
largest interline movements follow the basic operations
concept developed for system planning, so riders actually
do not have to get off the trains. Only 15-20,000 per-
sons daily would switch trains, which is a relatively
small rush hour volume of people. Therefore, addition-
al interline service connections and special additional
transfer stations do not appear to be necessary based
upon ridership. However, the impact on transfer move-
ments and rider access to the rest of the CBD became
significant elements for transfer analysis.
3.2 Service Connections
With a large yard and shop facility being built in the
unincorporated area adjacent to Hialeah as part of Stage
1, the need to phase in several future transit lines and
the necessity to accommodate interline rail movements,
the question of service connections is a serious concern.
•
t
.11i11111111u1■11uIII IIu■IIII■■
E
�•
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ME
if equipment alone could be moved from Stage 1 lines
onto future extensions, future yard costs could be re=
duced and new lines phased in more easily than operating
independent lines each with their own yards and shops.
Attempts to see how various alternatives could accommo-
date primarily a "non -revenue" service connection, and
secondly an interline service connection were initiated
as part of the alternative analysis.
3,3 Land Use Impacts
While it is presumed that the Stage 2 line would be
accommodated within the Government Center, the position
of the platform, the impact of the Stage 2 line on
Lummus Park, the areas east of the FEC railroad,and im-
pacts of varying levels in the Washington Heights area
all became vital issues requiring further analysis.
Opportunities to allow private development near the
Stage 2 station, bring riders closer to the CBD core,
and minimize land acquisition or displacement to residen-
tial areas, all required further analysis as well.
3,4 The Detailed Alternatives
After review by various agencies, refinements to the
four original alternative concepts were produced by
staff. These so-called "centerline" alternatives gave
more careful attention to engineering details as well
as architectural, land use, and operational elements.
The nine alternatives fall into four basic groups.
Three of the four groups were first covered in the ori-
ginal scenarios. The fourth is a resurrection of the
original preliminary engineering scheme whereby direct
rail service is carried toward Biscayne Boulevard and
other parts of the downtown area. The four basic groups
are:
. 1 Stub -End Service at Government Center
A future east -west line would stub -end at the Stage
1 Government Center station, and a northeast line
would stub -end at the Washington Heights or Govern-
ment Center station.
. 2 East-West/Northeast Line Connection via Government
Center
Five different design concepts were developed which
would allow a single, through service rail line to
connect east -west and northeast lines into a single
rail line. The placement of the Government Center
platform on this line, its impact on the Stage 1
line and impacts to the Government Center or areas
just east of the CBD differ among the five alignments.
1
6
■IIIIIIIIIII_II IIIII■IIuuuIIiII IIIi a iIuI■■n■■
•
1
„5 y s_t 4est/Nottheast,. title Coniie,cted__Via Washington
eights
An east -west line would follow a N.W. 7th Street
alignment into a refined Stage 1 Washington Heights
alignment, with service continuing into a northeast
line.
.4 Extended East-West/Northeast Line Connection
Two alternatives propose to carry the east -west line
through Government Center eastward to the Biscayne
Boulevard corridor, then northward to make a north-
east line connection and/or loop back to the west
to tie into the Hialeah portion of Stage 1. Each of
these alternatives assumes the preliminary engin-
eering alignment of the east -west line crossing
of I-95 from the west.
Figure 3 on the following page is a matrix which
summarizes the impacts of these alternatives.
The specific alignments of the nine alternatives
are shown in Figures 4 through 12 on the following
pages.
6
■I■..■uiiuiii.I 1111111111 IIIIIIIuu i111111iiiiimimiiwm
y' sta'West/Northeast tine Connected via Washington
tt,ights
An east -west line would follow a N.W. ith Street
alignment into a refined Stage 1 Washington Heights
alignment, with service continuing into a northeast
line.
Extended East-West/Northeast Line Connection
Two alternatives propose to carry the east -west line
through Government Center eastward to the Biscayne
Boulevard corridor, then northward to make a north-
east line connection and/or loop back to the west
to tie into the Hialeah portion of Stage 1. Each of
these alternatives assumes the preliminary engin-
eering alignment of the east -west line crossing
of I-95 from the west.
Figure 3 on the following page is a matrix which
summarizes the impacts of these alternatives.
The specific alignments of the nine alternatives
are shown in Figures 4 through 12 on the following
pages.
IIIIIIII
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FTGlJRE 3
THE FOUR BASIC ALTERNATIVES
II111111I IIII
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Scenario 1
Scenario 2
Scenario 3
Scenario, 6
Land Use Impact
Minimum
Require additional ROW for
curve west or east of Govern-
ment Center.
Curve could require addi-
tional ROW within Govern-
ment Center.
Curve would- require addttionoI1
ROW within Government Center
Stage 1 Profile
No change
Possible shifting of horizon-
tal profile to accommodate
Stage 2 tracks.
Government Center station
relocated further north.
Possible shifting of hori-
zontal profile to accommo-
date Stage 2 tracks.
No vertical or hortzontal
problems.
Stage 2 Profile
Possible vertical
profile problem
Station platform of EW line
location affect vertical
profile, curve passes
through Government Center
complex.
Stage 2 profile dependent
on 1-95 and passage beneath
Stage 1.
No vertical or horizontals
problems.
Government Center Station
2 level platforms.
Major transfer point.
Station platforms would be
separated or "L" shaped.
Stage 1 platform moved
Slightly northward.
Station located further to
the north. 2 parallel
platforms required.
This station could be defer-
red to Stage 2.
No direct access to Stage 2`..
Transfer to Washington Heights,
required.
Washington Heights
Station
No impact
Provision of Stage 2 tracks
at this station. Possible
transfer point. This
station could be deferred
to Stage 2.
Relocation of Government
Center station could elimi-
nate need for this station.
Would have to accommodate
4 tracks.
Primary transfer station
between Stages 1 and 2.
Stage 2 transfer to Government
Center.
DPM Interface
No problem
Stage 2 platform would
not he directly served by
DPM without some walking
distance.
Government Center DPM stop
moved further north, possibly
combining the 2 proposed
stops.
DPM would have to be extended
to Washington Heights to
directly serve Stage 2.
Transfers
Concentrated at
Government Center.
No through EW to WE
connection.
A short walk would be re-
quired for Stage 1 and
Stage 2 transfers at the
Government Center. Through
EW to NE movement possible.
All transfers at Government
Center or Washington Heights.
Through EW to NE movement
possible.
Washington Heights the only
transfer point. Must be
des! A for transfer load.
Stage 2 Operations
through NE to EW
service. No NE
service.
provision. EW trains
reverse at Government
Center.
Uninterrupted EW to NE
Line connection without
interference with Stage 1
The NF. connection could
he deferred depending on
phasing.
Uninterrupted EW to NE
line connection without
interference with Stage 1.
The NE connection could
be deferred depending on
phasing.
All trips to Government
Center must transfer.
Switching required on sharedS`
trackage. Headway problems
would occur.
Rail Equipment
Movement
No service connection
provided.
Service connection would
be provided at Washington
Heights.
Service connection would
he provided at Washington
Heights.
Service connection on shared
trackage.
11111111111
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FIGURE 4
ALTERNATIVE I
EAST -WEST LINE STUB -END
II
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lull
11
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11
11
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lull
11
11
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1
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FIGURE 5
ALTERNATIVE 2
EAST -WEST LINE AT RIGHT ANGLE
SEPARATED PLATFORMS
AVE c-•
Fgi
4 4[
1-BISCAYNE SOWVARO
Ns
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i
i
i
1
i
i
1
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II■ ON1111111111111111111111
FIGURE 6
ALTERNATIVE 2A
EAST -WEST LINE AT RIGHT AN(:L.E :
CONNECTED PLATFORMS
L.
nL
[Foul
IL
RISCAYNI ROUtFVARO
1 _Lif
MI
IOuI
FIGI►RE 7
ALTERNATIVE 3
EAST -WEST LINE AT ANGLE SW TO NE
SEPARATED PLATFORMS
uII
II
1
11111111111111
1
111111111
I
1
I
1111111
11
■III
111111111111
BISCAYNE BOULEVARD
i■■iiiiiiuiiiiiii
FIGURE 8
ALTERNATIVE 3A
EAST —WEST LINE AT ANGLE SW TO NE
CONNECTED PLATFORMS
—1{1...----- e1sGYNE sou«YARD
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••11 111 1111111
1111111111 i11 111 1I1l 111IlU1uiiii iiiiiiii ■
�-1
NE
ALTERNATIVE 4
EAST -WEST LINE TURNING: IN GOVERNMENT CENTER
PARALLEL PLATFORMS
S ._� AVTY ,
RISCAYME SOUIIVARO
■
11
■
i
i
i
i
1
111111111
1
'ID"
1111
1
I■IiI'
i
IIII
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i
11
i.ui.
FIGURE 10
ALTERNATIVE 5
EAST=WEST LINE OUTSIDE GOVERNMENT -GE
11111 II
11111
11
111111111111
1111
111111111111111111111111111
i
i
i
i
i
I
I
i
I
i
■
111
IIII
1111
1
1111
I
i
1=111111111
11
11
1111111
11
111111
FIGURE 11
ALTERNATIVE 6
EAST -WEST LINF THROUGH CRD
NORTHEAST CONNECTION VIA NE 2 AVE
a
C•
iAn
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1111
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I_
❑-
WA-
Fij
!
war-
MEM
L
l
i
1
.01 d
l� �y
01sc ABM[ sOUIEVAAO
1•1111111111111
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NI
11111110111111111111111111111111111
FIGURE 12
ALTERNATIVE 7
EAST -WEST LINE THROUGH GREY
NORTHEAST CONNECTION VIA WASHINGTON H'E!GWTS•
17
4it APPLICATION OF EVALUATION CRITERIA
in order to provide a basis for judging the relative merits
Of each of the alternatives chosen for detailed study, staff
prepared a set of evaluation criteria against which each
alternative could be measured. The criteria began with a
statement of the problem and the goal being sought, and follow-
ed with a set of objectives to be achieved in design and oper-
ation of Stage 1, particularly in the Government Center area.
Following is the statement of objectives which comprise the
evaluation criteria.
4.1 Ridership
To provide efficient and convenient movement of pass-
engers throughout the transit system.
. 1 Passenger travel on the rapid transit system to
both the Government Center and downtown destination
(particularly as this travel relates to the DPM)
should be efficient and convenient.
. 2 Rapid transit stations should be located and
designed to minimize passenger inconvenience and
total travel time to these destinations.
. 3 Stage 1 and future transit lines should be con-
figured so as to minimize transfer movements.
• Walking distances between transfer points should
be minimized.
.5 Where practical, more than one transfer location
between rail lines should be provided.
4.2 System Operations and Service Connections
Rapid transit design and configuration should provide
for reliable, efficient, and flexible system operation.
.1 Non -revenue service connections between all lines
should be provided to allow efficient and balanced
operations and maintenance.
.2 Where practical, line extensions should be connected
with each other to allow through train movements,
reducing possible turnaround activity in the Govern-
ment Center area.
. 3 Design standards should be adhered to while taking
into account line -segment and/or site -specific
characteristics.
•
•
1 S
benign fot futute extensions should allow fot the
possibility that any ot all ptoposed lines may not
be built, and that future extensions may be subject
to changes in proposed alignments.
1, Rapid transit design and configuration should harmonize
tith existing and planned land uses in the Government
Center and adjacent areas to the fullest extent possible,
.1 Disruptive land acquisition should be avoided, such
as public amenities (parks, historic sites, etc.)
expensive structures, or acquisition requiring re-
location of residents and/or businesses.
62 Rapid transit design and configuration must not
adversely impact existing or committed components
of the Government Center plan.
63 Adverse visual and noise impact associated with
transit design should be minimized.
64 Encroachment of the system into adjacent parts of
CBD and residential areas should be minimized.
.5 Washington Heights station location should be
acceptible to the community and harmonize with
CBD development programs.
Following further discussion and evaluation of the nine
alternatives, four concepts were chosen for detailed
study.
These criteria form the basis for the first level of
screening of alternatives. The screening process amounted
to a detailed application of one criterion to each alter-
native, weighting ridership at 50%, operations at 35%,
and land use at 15%. The application of these criteria
to the nine alternatives is shown in Figure 13 on the
following page. Essentially, Figure 13 demonstrates the
primary reasons for the selection of the four alternatives
identified for final evaluation. Alternative 1 was selected
because it is the base alternative; that which presently
exists. Alternative 3A was selected because it permits
a continuous east -west to northeast connection, and
interfaces well with Stage 1 and the DPM. Alternative
5 was selected because its impact on Government Center
would be minimal. Alternative 6 was selected because it
permits a continuous east -west to northeast connection
through the Miami CBD, complementing the DPM.
1111111111
111111II III
1
11111111111
INI111111111111111111
IIIIIIIIIIII
1111111111111111111111111111111111111111111111111111111111IIIIIIIIMIlliiiiiiimm
FIGURE 13
SUMMARY OF IMPACTS ON THE GOVERNMENT CENTER
Alternative
Stage 2
Direct
Platform
Connection
Possible
Stage 2
EW-NE
Through
Service
Possible
without
Transfers
Stage 2
Service
Connection
to Stage 1
Possible
Stage 2
Revenue
Connection
to Stage 1
Possible
Major Modi-
fications
to Stage 1
Line Required
to Accommodate
Stage 2 Line
Stage 2
Impact on
Covernment
Center
Future Extensions
Impact on other
Adjacent Areas
& Land Use Plan
i
Stage 2
Accommodation'
of Transfers
. Stage 2'
Accommodation ,
of CBD Riders
14
2
2A
3
3A4-
4
4
64
7
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
Yes
Yee
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yea
No
Yea'
Yes'
1
Yes
Yes
Yes1
Yes1
No
Yea
No
No
go
No
No
Yes
Yes
No
No
Minimal
Minimal
Minimal
Modest
Minimal
Modest
Minimal
Minimal
Minimal
Substantial2
Substantial
Substantial
Minimal
Substantial
Minimal
Substantial
Very Substantial
Very Substantial
Poor
Fair
Good'
Fair
Goods
Good)
Poor
Good!
Goodf
Good?
Poor
Good!
Poor
Good
Fair
Very Poor
Very Good'
Very Good'
I Would require more detailed analysis to determine feasibility.
Anticipates 1000' tail track (standard system requirement for overshoot).
3 Assumes completion of DPM system.
Selected for final analysis.
1111111111111111111111111111111111111111111111111111
20
SA LEVEL 1W0 SCREENING OF DESIGN APPROACHES
t:l Alternative Design No. 1
This alternative is based on the stub. -end tetfiinatioh
of the east -west and northeast Stage 2 rail line at
the Government Center. There is no connection between
the east -west and northeast line or the east -west with
the Stage 1 rail line. A service connection is provided
between the northeast line and the Stage 1 line.
The east -west line follows the Preliminary Engineering
dlignment into the Government Center, but terminates
at a right angle to the Stage 1 Government Center station
platform and at the same elevation as the Stage 1 platform.
There is no provision for a tail track. Trains would be
reversed in the station and return via crossover tracks.
Elevation of the top of the rail at this station is 59 feet.
The gradient over I-95 is 3.0% and all curves are within a
1,000' radius.
The northeast line enters the study area via the FEC
rail line running immediately adjacent and parallel to
the Stage 1 alignment from Washington Heights terminating
at the Government Center. A service connection is pro-
vided at Washington Heights. The Government Center
platform is staggered approximately 100' north of the
Stage 1 platform at the same 59' elevation, requiring
a 3.0% grade to reach the platform at which point the
line is terminated with no tail track. Reverse move-
ments are made via crossovers north of the platform.
There are no curves required for this portion of the north-
east line.
This alternative requires an extended platform for the
east -west line through the Government Center, provisions
in the Stage 1 Government Center station for extended
mezzanines and platforms, and provisions in the Washing-
ton Heights station for a service connection crossover
and adjacent parallel tracks. This plan does not pro-
vide through east -west to northeast revenue or non -revenue
operation nor does it allow a service connection for the
east -west line to Stage 1. The system would be operated
as three separate lines, two terminating at the Govern-
ment Center. All transfers between Stage 1, the east -
west line, and the northeast line would necessarily take
place at the Government Center station.
5.2 Alternative Design No. 2
This alternative provides a through connection of the
east -west line with the northeast line via Downtown
Miami, with transfers between Stage 1 and Stage 2 occurring
at the Government Center station.
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ALTERNATIVE
EAST
I53
FIGURE
-WEST
LINE
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14
DESIGN
STUB
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1
-END
s
. Transportation Improvement Program
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERN)okTIVE CONCEPT 1
THE KAISER TRANSIT GROUP a pint ventur•
A A:SER ENG.NE EPS POST TAXA I. t T SCHUH & JERNIGAN. RC
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THE KAISER TRANSIT GROUP a plot venture
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FIGURE 15
ALTERNATIVE DESIGN 2
EAST -WEST LINE AT RIGHT ANGLE
GifVEn'i''',ENT CENTER
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE_SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 2
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5.3 Alternative Design No. 3
This alternative provides a through connection of the
east -west line with the northeast line. Stage 2 inter-
sects Stage 1 at an angle at the Government Center station
with a curve located west of Miami Avenue. A service
connection is provided between Stage 1 and Stage 2 lines.
The east -west line follows the PE alignment into the
Government Center following a slight southeastward
alignment before curving to a northeastward alignment
with a 750' radius curve. Between I-95 and immediately
west of Stage 1 this line descends at a 3.0% grade to an
elevation of 39.0 feet, at which point the Stage 2 Govern-
ment Center station platform is situated at an angle be-
neath the north end of the Stage 1 platform. A slight
0.3% downgrade is retained through this station. The
Stage 2 platform is located primarily east of the Govern-
ment Center boundary extending to the northeast across
N.W. 1st Avenue and N.W. 3rd Street. The line then curves
through four blocks of low rise or vacant commercial devel-
opment, extending as far east as the immediate east side
of North Miami Avenue. At this point, it turns northwest
over the FEC Dodge Island spur to enter the main FEC
right-of-way immediately north of the Stage 1 Washington
Heights station. A service connection located on the
curve at Washington Heights would be made between the
Stage 1 and Stage 2 lines. The Stage 2 line continues
north leaving Stage 1 right-of-way passing beneath the
East/West Expressway and the northeast in the FEC right-
of-way.
•
All grades are within the 3.0% standard. There are no curves
within the Government Center; however, a turn would be
This alternative follows the PE alignment from the
tieSti crossing I-95 and passing through the Government
Center at a 3% downgrade to an elevation of 39 feet,
at which point it levels off at the Government Center
station. This station platform is at a right angle to
the Stage 1 platform forming a "T" shaped station. East
of Stage 1, the Stage 2 alignment follows Second Street
east several blocks and then turns north within the Bis-
cayne Boulevard corridor to become the northeast line.
required within the downtown to the northeast. Dis-
ruption in the Government Center is minimal. However,
passage directly through the downtown would require
special treatment to streets and some land area. While
mm
providing a direct east -west to northeast connection
mm
and direct downtown accessibility, this plan does not
provide a service connection between Stage 1 and Stage 2
and would require careful consideration of downtown impact,
particularly with respect to the proposed Downtown People
Mover system.
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GOVFRNAILNT CENTER STATION
EAST/WEST EXPRESSWAY
WASHINGTON HEIGHTS
5T 2N1
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VOK
j .n LAPPROtIMATE 'ExISThNG GPOUN
N E.CORRIQOR STATION
N. COF IDOtt
550 105 115 FIGURE 161125
ALTERNATIVE DESIGN 3
EAST -WEST LINE AT ANGLE SW TO NE
!N GO'.EP.N ENT CENTER
■•ansportation Improvement Program
■
THE KAISER TRANSIT GROUP a pint wntur•
RAISER ENGINEERS
&Y.*LU. V M►•, . ■A,!!. COWAM.
HARRY WEESE E ASSOCIATES LTD
APIaoVTc
POST BUCKS ET SCHUH A JERNIGAN. NC.
CARA SMITH AND ASSOCIATES INC
SCHIMPEI.ER CORRADINO ASSOCIATES
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 3
lc.sE l'•40'• VERT wAw•A SKC-190 I
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25
the Stage 2 alignment between I-95 and the East/West
Expressway requires 3 curves separated by tangents;
two of which (on each side of the Government Center
platform) have a 750'radius; the third has a 1,000'
radius. All grades are within the 3.0% standard.
The service connection requires a crossover on a curve:
however, the direction of normal revenue operation is
"with" rather than "against" turnout points, reducing
any potential safety hazard. This plan requires acqui-
sition of right-of-way between N.W. 1st Avenue and North
Miami Avenue and N.W. 3rd Street and N.W. 8th Street.
A curved alignment is required through the Government
Center, but the Stage 2 platform will lie primarily
outside the Government Center with street access in
addition to access from the Government Center.
This alternative provides an east -west to northeast
revenue connection and a Stage 1 to Stage 2 service
connection. It does not provide for direct Stage 2
access to the Washington Heights station and all Stage
1 to Stage 2 transfers would necessarily take place at
the Government Center station. Land impact on the
Government Center is minimal, but right-of-way would
have to be taken east of Stage 1. The Stage 2 alignment
could affect DPM routes through this area.
5.4 Alternative Design No. 4
This alternative represents a departure from the others
in that it assumes an alignment for the east -west line
along N.W. 7th Street and intersects Stage 1 at Washington
Heights rather than the Government Center. It provides
a through east -west to northeast line connection, but
does not include a service connection between Stage 1
and Stage 2 (although one could be accommodated). There
is no direct Stage 2 connection with the Government Center.
The east -west line crosses I-95 from N.W. 7th Street on
a 3.0% grade west of I-95 and a 1.0% grade east of I-95
at which point it remains at an elevation of 59', curv-
ing northeast to pass over Stage 1 at Washington Heights.
At this point of intersection the Washington Heights sta-
tion forms an "x" arrangement requiring right-of-way
acquisition around both platforms. This station is the
only Stage 1 to Stage 2 transfer point. The Stage 2
alignment joins the FEC northeast right-of-way at N.W.
llth Street passing below the East/West Expressway
forming the northeast line.
This alternative has no impact on the Government Center
with respect to future rail extensions. The Washington
Heights station becomes a major transfer location. It is
important to note that this plan requires a relocation
of the Washington Heights station and is not feasible if
the station remains in the approved Stage 1 alignment.
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m 100
110
unty Transportation Improvement Program
THE KAISER TRANSIT GROUP a pint venture
AAISER ENGINEERS POST Bur.ALET SCHUN A JERNIGAN. INC
pvrlKl. O• W..• J •ufi. COtl•Arr CARR SYh'N AND ASSOCIATES INC
HARRY WEESE A ASSOCIATES LTD SCHairt:EN CCARAD.NO ASSOCIATES
FIGURE 17
ALTERNATIVE DESIGN 4
EAS'-'WEST LINE OUTSIDE GOVERNMENT CENTER
STAGE II TRANSIT STUDY
INTERFACE WITH
LINE SECTION 4 FACILITIES
ALTERNATIVE CONCEPT 4
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While this plan eliitinates the need for provision of
future facilities at the Govetnment Center, it does
fequire the relocation of the Washington Heights
station and provision for the Stage 2 platform and
tight -of -way. All Stage 2 riders destined for the
Government Center or the Miami CBD would be required
to transfer to Stage 1 trains to get to the Government
Center station.
5,5 Analysis of Final Alternative Designs
The four final design alternatives developed have had
their various features summarized in Figure 18 to facil-
itate comparison. Figure 18 is a matrix highlighting
the different impacts of each alternative, and thus
summarizes detailed analysis of the different schemes.
The alternatives were evaluated against the criteria
listed in Section 4.0 of this report. Based upon the
criteria, the four alternative designs fell into two
categories: Acceptable and Unacceptable. A discussion of
these rankings is as follows.
.1 Unacceptable Alternative Designs
Based upon the criteria discussed earlier in this
report, design concepts No. 1 and No. 4 have major
deficiencies which make them unacceptable design
alternatives for future planning. Their shortcomings
which result in their elimination from further con-
sideration are as follows:
Alternative Design No. 1
Summary of deficiencies
• Poor rail operating conditions
• Inadequate rail passenger transfer conditions
• Lack of service connection
• Substantial land use impacts in the Govern-
ment Center itself to accommodate additional
platforms
Cost: $29.350 million
The very poor transit operations environment and
passenger accommodations created by placing two or
three stub -ended lines in the Government Center, makes
this design concept undesirable. Storage and cross-
over space in the Government Center would be needed to
make stub -ended configurations work. A relatively high
price would be required for this concept.
aMg
28
A1tetilatiVe benign Nos 4...
guTfaty of deficiencies
i Poor service connections
i Inconvenient passenger thovetnetits
i Substantial land use impacts iti Washingtoh
Heights area counter to apptoved Stage l plans
i No DPM interface
Cost: $13.750 million
The major disruption this concept causes in the
Washington Heights area is counter to approved neigh-
borhood plans and citizens' desires. While this is the
least expensive scheme, it would cause many addition-
al passenger transfers as riders try to get to the
Government Center from the east -west lines. Finally,
the lack of interface with the DPM system is contrary
to public policies.
.2 Acceptable Alternative Designs
Both alternatives No. 2 and No. 3 were judged to be
acceptable for future planning purposes even though
they are substantially different from each other.
Both schemes avoid operational problems, unacceptable
land use, or ridership problems encountered in the
other two alternatives previously discussed. However,
alternatives No. 2 and No. 3 have both positive and
negative facets which need to be brought forward and
analyzed.
Alternative Design No. 2
• Rail operating conditions are good
• Rail service connections are poor
• Optimal transit rider accommodations and
travel time savings
• Very substantial land use impacts in the CBD
• Conflicts with DPM policies
Cost: $31.775 million
This concept, which is similar to many early pre-
liminary engineering proposals, runs the east -west
line across the CBD around 3rd Street. While this
provides the highest level of transit rider service,
it also produces the highest level of land use impacts
(including disruption to Southern Bell operations),
will have negative impacts on DPM usage, and would be
the most difficult and costly to build.
29
■
•
MM
■
1
l .fi.&t_ive_. Design No_, ,3
Rail operating conditions are good
i Only alternative providing a service
connection
i Good rider and destination
transfer
accommodations
Substantial land
Government Center
Good DPM interface.
use
Cost: $20.750 million
impacts east of the
This concept has the rail operating characteristics
of through line service, and allows inter -line
service connections, DPM interface, and good rider
movements between lines and to their final destina-
tion. There will be major land use impacts just east
of the Government Center. There is also the possi-
bility of modifying the northern line to parallel
Miami Avenue into the Buena Victa _yards and realign-
ment of the line section through the Government
Center adjacent to N.W. 2nd Street. The cost is the
second lowest of the four design alternatives.
29
IIIIIIIII IIIIIIIIIII III■1111111111
•
•
t0X0.ti,te Design No..3
i Mail operating conditions ate good
i Only alternative providing a service
connection
to Good rider transfer and destination
accommodations
to Substantial land use impacts east of tht,'
Government Center
i Good DPM interface.
Cost: S20.750 million
This concept has the rail operating characteristics
of through line service, and allows inter -line
service connections, DPM interface, and good rider
movements between lines and to their final destina-
tion. There will be major land use impacts just east
of the Government Center. There is also the possi-
bility of modifying the northern line to parallel
Miami Avenue into the Buena Vista yards and realign-
ment of the line section through the Government
Center adjacent to N.W. 2nd Street. The cost is the
second lowest of the four design alternatives.
11111111
i
i
I
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i
iiritir IN
Tv: FTLR AI TFRVATIVF. HfciC.NS
St3QtARY of t,IARAf:rFRTSTIrS
Alternative Dentin 1
Alternative Pest 2
.iuiuiiuuiiiiui
Alternative Demlan 3
11
11
11
11
Alternative Vestatr 6<
Line charmctert•tics
Three linen: 1. Rtaleah-
Dedelend. 2. Little Havana-
Government Center. 1. North-
emit Ded►-Government Center.
Two linen: I. Rlaleah-Dade-
land. 2. Little Havana -North-
rant Dade via Miami CPO.
Two linen: I. Rteleah -Dade -
lend. 2. Little Novotny-
Northeast Dade.
Two tines: I. Hialeah -
Dadeland. 2. Little Navanm-
Northeast Dade vts Wanhtna-
ton Neightn.
Station Configuration
Government Center: two
parallel plwt(nr.w end •
third at right angle to
went. all at wean (Se') el-
evattrm. Manhington RelghtAl
two parallel platforms st
tame (37') elevation.
Government Center: Line 2
p - ender Line I at
right angle. WoshinAion
Goverment Center: Line 2
p -_— _ .mder north end of
Line 1 platform at angle
of approximately iS".
Washington Height.: name
en Stoop 1.
Government Center: Noe
affected, 4wwhtn&ton Hetahtmt
Line 2 pssnes over north epee
of Line 1 platform at rnlahle
rtaht natl...
NeiRhta: none nw [rage 1.
Operational Characteristic,
Line 1: N/A. Line 2: none
Line 3: none.
Line I to Line 2: no. Line 2
to Line 1: no. Line 3 to
Line 1: yea.
Difficult
Line 1: N/A. Line 2: N/A
No
Good
Line 1: N/A. Line 2: N/A
Tea
Good
Line 1: N/A. Line Z: ION
No
No
•. Tall tracks
b. Service Connections
c. DP( interface
Passenger Service
a. CAD/Government Center
destination
b. Civic Center destination
e. Little Savona -
Northeast Dade Service
Line 1 from north i south:
good. Line 2:Rnod. Line 3:
good.
Lino 1 from north i south:
Rood. Line 2:tranafer re-
utred. Line 3: fer re-
gutted.
Transfer required
Line 1 from north i south:
gond. Line 2 from east &
teat: good.
Line I from north & south:
(!nod. Line 2 from pent i
went: transfer regnlred.
Through service
Line 1 from north i south:
good. Line 2 from pant I.
teat: good
Line 1 from north i month:
Rood. Line 2 from cent i
vest: transfer remitted.
Through service
Line 1 from north C mouth:
Rood. Line 2 frommaat a
vent: trnnafer reeulred'.
Line t from north & south:
gond. Lin, 2 from ewer S.
..eat: transfer required:
Thrnuah 'service
Lend Dee Impact
a. Within Government Center
b. Adjoining
Mtniaml
Minimal
Minimal
Very suhstantlal
Minimal
Sob lel
Nnne
Suhetantisir
totimated Coat (197A dollars')
S29.150.000
S31.775.000
S20,250.000
$I3.750',D00
Commtents
- -
rotation
Gnvertlment Center s
fe rnnpllrnted. Lark of tail
treat,' not ronntntent with
•)stem safety 'specifics-
firma. No nervier rnnnectlnn
between fine 2 and rent of
ovate'. Stage 2 rnnatnrr-
tlnn dlaro'tive to Stage 1
operatlong .
No service connection
between lines'.
Provides' additional
downtown servtee.
Only alternative providing
nervier connection. Requires
additionai right-of-vnv vest
of Cov►rnnent Center.
-
Requirerelocation oft
s
ttnchinRton Height..
',tenon from approved'
location on Stage [-
11
IIIIII III
0
i_ •
1
mMikW
31
6 CONCLUSIONS
While none of the altetnative design concepts offer ati
ideal situation, the immediate differences between the tiny
acceptability of alternatives No. 1 and No. 4, vs. accept-
able designs No. 2 and No. 3 are evident from land use, set
vice, and ridership viewpoints. Thus the rationale behind
the initial rejection of alternatives No. 1 and No. 4 is
clear.
The differences between No. 2 and No. 3 are in many ways
also decisive. Alternative No. 3 is less disruptive, both
within the Government Center and in the CBD;is less costly,
has better coordination with and does not compete with the
DPM, and allows inter -line service connections and good transit
rider accommodations. Alternative No. 2 suffers by compar-
ison on these issues and is therefore less satisfactory.
Alternative No. 2 has a singular advantage in its ability
to carry transit riders directly into the heart of the CBD
and allow possible private redevelopment adjacent to the
right-of-way. While this is desirable,based on ridership
demands and the heavy loads that the DPM might be burdened
with,Alternative No. 2 represents a major departure from
currently adopted policy, is far more expensive, and has
operational drawbacks which negate its ridership advantages.
Therefore Alternative No. 3 and its possible modification
represents the clearest choice for future Stage 1/Stage 2
interface at this time. Future investigation could modify
Alternative No. 3 into a scheme that offers better CBD pen-
etration or replaces the DPM in certain areas dependent
upon the final design concepts advanced for the DPM and CBD
development schemes. The flexibility of Alternative No. 3
is therefore unique in that no other alternative design
could allow as much future modification potential. The choice
of Alternative No. 3,with slight profile and alignment changes
to make it fit into the Government Center as easily as possible,
appears by all evaluation standards to be the optimal choice
for future planning efforts.
•
•
•
t`I1 6F`' M1AHl, a Platicta
:1 t hidipal borpbratieh,
Petitioner,
S'Pti JOE PAPER COMPANY, etd. ,
• et al„
Respondents:
.Mt COtPt 6P LO bA
Et Not si,37�
PETITIONER'S MOTION FOR. RE-
HEARING AND FOR CONSIDERATION
OF CONSTITUTIONAL PROVISIONS
AND A POINT OF LAW NOT DEALT
WITH BY COURT'S OCTCBER 5,
1978 RULING
Petitioner, City of Miami ("City"), respectfully mo'fes
this Honorable Court to rehear and reconsider its order and
opinion in part affirming and in part discharging certiorari
in this cause, and for the Court to consider and rule upon
constitutional bases and a point of law not addressed by this
Court's October 5, 1978 decision.
As grounds therefor, the City would show unto the Court
as follows:
1. This cause is before the Court on "questions of great
public interest" jurisdiction, not upon "direct conflict"
jurisdiction. See Florida Constitution, Article V, Section
3(b)3.1
2. The question certified is whether Florida Statutes
Chapter 712 can constitutionally be applied to divest the City
of a grant deed to state soverignty land.
3. This Court has properly approved the City's contention
`that respondent's putative root of title is a wild deed.
4. But this Court has rejected the City's challenge to
•Chapter 712's constitutionality if it is held to apply to a
wild deed.
5. The Court has indicated that other states have approved
the constitutionality of marketable title acts, but has over -
:looked the fact that such approvals of constitutionality came only
by construing such statutes as not according validity to wild
'The propriety of a partial affirmance and a partial discharge of
certiorari is therefore unclear.
BAILCT i OAwES.A PROFESSIONAL ASSOCI•TaON
SUITE IO2O,ONE BISCAYN[ TOWER, TWO SOUTH BISCATNE BOULEVARO.MiAMI,, LORIOA 33131 TELEPHONE 130E. 3'4-6!OS
I uIiii innIit ■ iim
•
•
Si See tkehanae'.r,E11, Bank V, tawndale, Bang, 2 3
01B42d 191 (1t1. 1968); 4?ichel^an v, Messner, 33 N,W,2(1 800
(`Minn. 1951).
6, The Court has misperceived the thrust of the City's
arciuinent as being a blanket attack on all retroactive statutes,
Without conceding the point, but accepting for argument's sake
that retroactive legislation may be constitutional, the point
here is that the City needed two kinds of notice to be constitu-
tionally deprived of its vested rights. One, it had: notice of
passage of Chapter 712 in 1963. The second, it did not have:
'notice that there was an adverse claim to its property. This
Court's opinion deals only (and at length) with the first kind of
notice. But the Court fails to deal with the second.
7. Until this opinion, the law of Florida has always been
that a wild deed does not affect property or constitute valid
notice. That law was plainly part of the statute. See U.S.
Trust Co. v. N.J., 97 S.Ct, 1505, 1515 Note 14 (1977) and
'authority cited.
8. Until this Court's opinion, no statute, rule, principle
or case law held that Chapter 712 (or any statute like it) became
.-operative by virtue of a void instrument.
9. Unless Chapter 712 is now construed to require that all
vested property right owners must re-record all deeds to protect
their property, it must be recognized that the 1944 wild deed did
not trigger Chapter 712 as to the City.
10. Therefore, the Court's discussion,as to retroactivity of
the statute cenerally,misses the mark. Florida constitutional
decisions have always before recognized that void instruments do
not accord the notice required by due process. This Court's
opinion fails to address or to acknowledge that issue; yet the
issue is critical to the Act's constitutionality.
11. This Court acknowledges that the City claims to be an
agency of the state and therefore excepted from the Act's purview.
But the Court fails to address the decisions holding cities to
be agencies. Instead it points to the language of Florida Statute
OAILEY b DAWES,A PFCrESSIONAL ASSOCIATION
SUITE ,82O.ONE HISCATNE TOWEH,TWO SOUTH SISCATNE BOULEVAFD, MiA 1, CLOAIDA 33,31 • TELEPHONE ,a ns•3T. S• O!
•
iii IIIIiuuuiiuiiuiii.iii
•
•
A'e1• 1i,Ydt'(1) x gut that reference has no bearing on the
envy cquestion. Admittedly the City is "singular" "governmental"
'vnd."dorporation" and therefore a "person" within Chapter
t so is the "state"and so is "any political subdivision
egeney thereof." Florida Statutes Chapter 712.01(1). If
Court reads Chapter 712.01(1) as determinative; then it must
read out of the Chapter the prevision
simply incorrect to hold that Chapter
12. But accepting the Court's clear
712:
or
the
of Chapter 712.04. It is
712.01(1) is determinative.
holding that the City
is, for purposes of the Act, just like a private corporation,
the Court's opinion fails to deal ,`ith the necessarily con-
comitant result -- the state has deprived the Cit.: of a vested
property right and,/or a constitutionally protected contract
ri=yht2 without compensation.
13, For this Court has failed to address two ether constitu-
tional attacks on this application
of Chapter 712: even when a
"taking" is accomplished with due process, and even when a
contract right is validly impaired under the police power, the
person losing the property or contract right must be fairly
compensated. See, e.g., C.S. Trust Co. v. N.J., supra, 1515
at Note 16. See also Contributors to the Pennsylvania
Hosc:ital v. City of Philadelphia, 38 S.Ct. 35 (1917) .
14. Indeed the construction placed by this Court upon Chapter
712 and its application here is inescapably an inverse condemnation
of the City's land. That the City's grant is full and ce.^.:plete
was recognized by this Court in TIFF v. Clauahton, 86 So.2d 775,
785 (Fla. 1956). That its ownership is proprietary and non -
.governmental has now been declared by this Court's October 5, 1973
ruling. That it has been divested by operation of Chapter 712 has
.also now been made clear. And that it has not been compensated
is obvious. The result of the Court's decision, therefore, is
that a private owner has been permitted, for reasons of Florida
public policy, to divest a city of land owned in its proprietary
-See U.S. Trust Co. v. N.J., supra, 1315 at 'Tote 14.
-3-
BAI♦..EY & OAWES A PNCJESSIONAL ASSOCkAT,ON
SUITE ,B&O.ONE BISCAYNE TOMCH, TWO SOUT., BISCAYNE BOUIEVARO,MIAMI, ELOPIOA 33131 • TE..EP..!}NE ,30b 374-51,: t
mOk
II 1111IIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIulIl
•
•
4t,fanle, V. Heim, 106 kali Rptr, 823 (Call \pp, 1973); People F�_Y
Oker+ 4 Cal, rptr: 334, 341 (Cal, 1960); People v, PoverOM0,
J59 N:Y.S,2d 343 (1973); In Re East River Drive, 289 N,Y,S, 433,
439 (1936), aff'd., 21 :; Y.S,2d 507 (1937); and Twombley v. City
of tong Beach, 333 F.2d 685 (9th Cir: 1964), cert, denied, 85
SiCt, 195 (1964).
19: The Court's discharge of certiorari is therefore predicated
4-o known statute, rule or precedent, The discharge of certiorari
is simply an ad hoc refusal to deal with a question of great public
interest,
WHEREFORE, the City respectfully requests this Honorable Court
to rehear its October 5, 1973 decision, to reconsider its discharge
of certiorari and to reverse the decision below,
Respectfully submitted,
BAILEY & DAWES, a professional
association
Attorneys for City of Miami
1820 One Biscayne Tower
Miami, Florida 33131
(305) 374-5505
By
�/ailcy, Jr.
WE•HEREBY CERTIFY that a true cop;' of the foregoing was mailed,
is 23rd day of October, A. D., 1978, to each of the following:
I. SHCTTS & BOWEN, 1000 Southeast First .rational Bark Bldg.,
Miami, Florida 33131.
2. SIBLE'i , GIBLI.I, LEVENSON & WARD, 1301 Dade Boulevard,
Miami, Florida 33139.
3. STLEL, RECTOR & DAVIS, 1400 Southeast First :rational Bark
. Bldg. , Miami, Florida 33131.
4. RUSSO, VAN DOREN & ALLEN, P.A., 4685 Ponca do Leon Blvd.,
Coral Gables, Florida 33146.
OrCour,sc.1
64.14EY & CAr,ES.o PRO, ESSiONA4 ASSCC.ATioN
SU17[ ,b20.Ot4E L CAYNE, TOY.ER.TKO SOUTH b,6CAYNE 13C,:,LCVARO,Alif-!.!!, r. O,:'DA 3313! • TE LrP,.01,4!' ICS 3,1 E
MM
MM
•
p Ci.Eya Honoring such a publid policy', hoWevers tenders the
ate liable to pa.: the city fair Value for the land the State
has allowed the private owner to take from the city.
15, Put another way, the Court's October 3, 1973 decision
fails to deal with the issues of (a) "taking" (just compensation)
and (b) impairment of contract. in the latter regard, the United
`States Supreme Court has, in two recent decision, made it abun-
dantly clear that either course requires just compensation. The
discussion in C.S. Trust Co. v, N.J., supra, at 97 S.Ct. 1515
through 1521, including the footnotes (14 through 27), and
especially footnotes 14,16, 17 and'27, plainly delineates the
constitutional proscription against Chapter 712's application
to these facts. See also Allied Structural Steel Co. v. Spannsus,
98 S.Ct. 2716 (1978).
16, This Court's opinion, as are all of the briefs opposing.
the City, are silent on this point. Surely this Court does not
mean silently to vitiate the t':o concepts from Florida's own
Constitution as well as to ignore the clearly reiterated mandate
of the Unites States Constitution.
17. Finally, and of critical necessity to the result reached
by the Court's October 5, 1973 decision, the Court silently
• accepts the state's unsupported position that the subject land
.•is not soverignt.: land. The state took this gratuitous position
in its anicus brief. The City sought leave to brief a response.
The Court never ruled upon it, "carrying it with the case."
Out of an abundance of caution, the City filed a proposed
responsiu brief en September 12. The Court's unexplained
discharge of certiorari and its declining even to accept the
briefs appears to indicate that the Court has never examined
the law on what is and what is not soverignty land.
18. As pointed out in the City's September 12th brief, evert_
discovered decision on the point indicates that the 1919 transfer
to the City did not and could not destroy the soverian nature of
the property in question. Ste U.S. .. State of California. 3>
S.Ct. 1401 (1965); 7nt' 1. Paper r- Co. v. ??is... St. Hwy. Ceet. , 271
So.2d 395 (Miss. 1973), ccrt. duniod 414 U.S. 827; Cc_:rnt ,moo
-4-
BAILEY & UAWES.A PPC,'ESSIONAL ASSOCIATION
SUITE I820.ONE BISCAYNC TOWCP, TWO SOUTH BISCAYNE BOJLEVAPA.M.A,MI,RO41EA 33,31 • T CLEPHONL'•f G`. ]: ^`Of
MM
MEM
MEM
•
•
dhge V, Reit, 106'tat, ?tptr, 825 (Cal, App, 1973); People T;_:
ker, 4 Cat, Rptr, 334i 333 (Cal, 1960)t People V, Poverote,
.359 .•i,Y,S,2d 343 (1973) ; In Re East River Drive, 289 'I,Y,S, 433,
439 (1936) , of 'd. , 21 :.Y.S,2d 507 (1937) ; and Twombley •i, City
Of Long Beach, 333 F,2d 685 (9th Cir. 1964), cert., denied, 85
S,Ct, 195 (1964).
19, The Court's discharge of certiorari is therefore predicated
on no known statute, rule or precedent, The discharge of certiorari
is simply an ad hoc refusal to deal with a question of great public
interest.
WHEREFORE, the City respectfully requests this Honorable Court
to rehear its October 5, 1979 decision, to reconsider its discharge
bf certiorari and to reverse the decision below.
Respectfully submitted,
BAILEY & DAS•iES, a professional
association
Attorneys for City of Miami
1820 One Biscayne Tower
Miami, Florida 33131
(305) 374-5505
By
Gu.. B. bailey , Jr.
TE:HEREBY CERTIFY that a true copy of the foregoing was .mailed,
is 23rd day of October, A. D., 1973, to each of the following:
1. SHUTTS & BO EN, 1000 Southeast First National Bank Bldg.,
Florida 33131.
2. SIBLEY, GIBLI::, LEVENSON & WARD, 1301 Dade Boulevard,
-Miami, Florida 33139.
3. STEEL, HECTOR & DAVIS, 1400 Southeast First :rational Bank
.Bldg., Miami, Florida 33131.
4. RUSSO, VAN DOREN & ALLEN, P.A., 4685 Ponce do Leon Blvd.,
Cord Gables, Florida 33146.
O Counsol
BAILEY 75, CANES,A PRO, ES91O!At. A„SCCIAT.O!+
rUITE 1820.Or,E BISCAYNE TONER,THO SOUTH b 5CArtlE (,C.,,,.EVA„E.,M.AMI, r,Of.OA 33131 • TCLFP•,(T,,r 3:.. 3,4..
11111111111111■1111111111111111111111111111111IOO11IIIIIIIIIIIIII IIU ilmiliIUIIIMIIII Iiimnn ui•
NCT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOT/ON AND, IF
FILED, DETERMINED,
IN THE SUPREME COURT CF FLORIDA
3b1.Y TERM, A. D. 1918
' iii a MIAMI, a Florida
cofPd:ationi
Petitioner,
Si. JOE PAPER CCMPANY, a
Florida corporation;
SOUTHEAST PROPERTIES, INC.,
a Florida corporation;
HUGH E. MATHESON, JR., •
individually; and SALLY S
bOMMERICH, formerly SALLY S.
MATHESON, individually,
Respondents.
Opinion filed October 5, 1978
Writ of Certiorari to the District Court of Appeal, Third District
Guy 3. Bailey, Jr. and Jesse C. Jcnes of Bailey and Dawes,
Miami, Florida,. for Petitioner
Wm. P. Simmons, Jr. of Shutts and 3owen, Miami; and Marion E. Sibley
and Eric
3 Mey
ers cf Sibley, G_ Levenson and Glaser, Miami Beach,
for St.Jce Paper Company;�JcsephLP. :Clock, Jr. of Steel, Hector
and Davis, Miami, for Southeast ?r per__es, Inc.; and Edmund P.
Russo of Russo, Van Ccren and Allen, Ccrai Gables, fcr Hugh E.
Matheson, Jr., Respondents
Nancy G. Linnan,ASS:Ste. General Counsel; and J.Kendrick Tucker,
Assistant Attcrney jeneral, Tallahassee, fcr Reu:in C'C. Askew,
as Governor cf the State cf r fcr ..a, and Reber_ L. Shevin, as
Genera_ cf the ._.._c s Curiae
Julian C. _lar :Son , John R. LawSCn, Jr., Hume F. Coleman and
Ches`.,Meld Smith cf Holland and Knight, Tallahassee, for ?micas
Curiae
J. Richard Harris of Scott, Burk, Royce, Harris and Loucks, Palm Beach,
fcr The Florida Bar, Amicus Curiae
DKIN9-, J.
This cause is here on petition for writ of certiorari
upported by certificate of the District Court of Appeal, Third
District, that its decision reported :n 347 Sc.2d 622 is one
which involves a ?uesticn of great public interest. We have -
jurisdiction. See Florida Constitution, Article V., Section 3(b)(3`.
I■ IIIIIIIIIIiiii■IIm111■1
•
Petitioner has attacked the ccnstitutiOnalitY of
ofide Statutes, Chapter 712, the Marketable Record Title ? t.
Also ihvOl.ed in this case is the question of whether an
interloping of wild deed could constitute a root of title.
Petitioner, hereinafter referred to as the city,
filed a complaint to quiet its title to a tract of land on the
north side of the Miami River at or near the river's entrance
into Biscayne Bay. Upon motion, the amended complaint was
dismissed on the ground that it appeared upon the face of the
complaint that the city's claim was barred by the Marketable
Record Title Act. The District Court of appeal, in its opinion,
recited the following history of the title, as described in the
city's complaint:
.1- In 1243, the State of Florida acquired
from the United States the lands under navi-
gable waters.
"2, By Warranty Deed recorded December 15,
1892, Henry M. Flagler conveyed to the
Florida East Coast Hotel Corporation, portions
of the mainland north of the Miami Ri•:er and
adjacent tc Biscayne Bay:
'containing fourteen acres, :sere or
less, together with all and singular
the riparian rights
and submerged
lands appertaining thereto.'
"3.By a special act cf the Florida Legislature
cnJune 2, 1913, the State of Florida Granted
tc the City
of Miami'`c municipal purposes
only, all its rights, title andinterest .
to all submergedlands, including waterfront
and riparian rights' to an area which included
the mouth cf the Miami River. The >tat.:to .
grant included the following sect -on:
*
"'Sec. 2. That this grant sha1l not affect any
other grant heretofore made to any individual or
corporation and nothing herein shall be con-
strued as depriving any riparian owner or
proprietor of an, rights under the laws of this
State.'
"4. Beginning in 1920, the Florida East Coast
Hotel Corporation bulkheaded and filled a portion
of the property in question but left a yacht
basin.
"5. On January 10, 1944, the St. Joe Paper Company
(cre of the defendants) recorded a warranty deed
from the Florida East Coast Hotel Corporation
which conveyed to it all of the lands with which
we are here concerned including the yacht basin
which was then in existence. Some time after
1944, St. Joe filled and bulkheaded the yacht basin.
2
•
-
O.
-°61 ail the defendant3 other than St. Joe claim
tinder tecorded deeds froth St, Joe Paper CoMpahy
Subsecueht to the 1944 deed to St. Joe Paper
'-ti hpan[.
°7. On February 3, 1949, St. Joe recorded a plat
(attached to the complaint) of the lands involved.
This plat was approved by the City of Miami prior
to recordation." 347 So.2d at 523 (Fla. 1977).
The Marketable Record Title Act is a comprehensive plan
refor:it in ccnveyahcing procedures. It is a curative act in
that it may operate to correct certain defects which have ariser.
the1
i execution of instruments in the chain of title. Curative
_ive
statutes reach back on past events to correct errors or irregu-
larities and to render valid and effective attempted acts which
would be otherwise ineffective for the purpose the parties
intended. They operate to complete a transaction which the
parties intended to accomplish but carried cut imperfectly.
The Marketable Record Title Act is also a statute of
limitations in that it requires Stale demands to be asserted
within a reasonable time after a cause of action has accrued. It
prescribes a per_ad within whir a right may be enforced.
The Marketable Record Title Act is also a recording
act in that it provides for a simple and easy .method by which the
owner cf an existing old interest may _reserve it. If he falls
to take the step cf filing the notice as provided, he has on.
y
himself to blame if his interest is extinguished. The legislature
di- net intend to arbitrarily wipe out old claims and interests
a me -f preserving them and giving a reasonable
without a- ,.. -_ _ means ., pr er --
period o: time within which to take the necessary steps to accom-
plish that purpose.
This court in .`.ahccd v. Bessemer Properties, Inc.,
18 So.2d 775 (Fla. 1944), held that the legislature may legiti-
mately use a recording statute as a :weans of getting rid of stale
claims. Florida Statutes 695.20, enacted in 1941, voided
contracts for the purchase of lands which were left by the
collapse of the Florida Real Estate boom of the 1920's. Under
the terms of the statute, persons who had contracted to purchase
.lard prior to a certain date but had not placed a deed en record
cr obtained a decree and were not in possession, were declared
3
•
•
•
41- 316 ifitereSt in the land unless they had given notice of
their,dlaims by recordation in one of several ways specified and
Within six Months frcm the adcpticn of the statute,
Catsman, the Marketable Record Title Act and CnifotM
Title Standards, Volume 3, Florida Real Property Practice (1965)
Section 6,2 describes the nature of the act as follows:
"The chief pur cse the act is tc extinguish
_r of ''
stale claims and ancient defects against the
title to real Jper__•, and, accordingly,
limit the pericdof sear:h. The act is
different from a statute of limitations. In
a statute oflimitations a claimof a vested,
present interest is cut off because of the
claimant's failure to sue. If suit is not
filed, the clam is lost. By the Marketable
Record Title Act, any claim or interest,
vested cr cc..__. -_.._, present or future, is
cut off unless the claimant preserves his
f
claim by filing
.. s notice within a 30-year
period. See 56.5. If a notice is not
filed, the clam is lost The act alsr gces
beyond a curative act. Curative legislation
o.r,i•: corrects Certain ^...r or technical
defects thrcugh passage of time, whereas
under the Reccrd Title Act, most
defects or clouds cn title beyond the period
of 30 years are removed and the purchaseris
made secure in his transaction."
This court has acrncwledged the pen-- ' 'enality of
the act in }Marshall v. Hollywccd, Inc., 236 Sc.2d 114 (Fla. 1970),
and Cdcn v. Cel__na Ccrperation, 341 So.2d 977 (Fla. 1976). We
nc:o spe'-' `• "a; 1, hcld that the :Marketable Reccrd Title Act is
constitutional.
Courts of other states have ruled that similar
marketable '• "e 'cts are CcnstitutiCnal. See Wicheiman v.
Messner, 33 NW2d 300 (Minn. 1957) (in depth discussion of the
r+Ct' fi CCriSt+• tuticnal_ty) Te=Cell .. Hanes, 32 rW2d 119, 123
(Iowa 1957) ("We are satisfied the legislature had ample authority
to make a limitation. . .sub:ect tc a ccndition that a reasonable
time must elapse befcre it beccmes effective."); Lang .. Traveler's
Insurance Con^.in;', 299 :74 553, 555 (Icwa 1941) ("1' `•t' doubt cf
the desirability of statutes giving greater effect and stability
to reccrd titles.") See also discussion in rore, Cons..-_UtiCn3li .
of Market Title :ecislati:n, 47 Icwa L.P..ev. 413, 42S-29 (1962) .
Cther decisi.:r.s by this court upholding the ccnstitu-
tioralit; of similar legislative enactments make it clear that
4
•
1
the ?,ct can onstitutionally be applied to bat the diet 3 claim,
3:t Mahood V. Bessemer Properties, Inc., supra, this Court upheld
tutio +•of the application, to a purchaser under
the Constitutionality •.
A 1925 contract, of a 1941 act which removed from titles to
fealty the clouds of unperformed Contracts of record unless suit
within months. In P.e Estateof Frown. 111 Sc.2d
be brought wi _ �n six ^••
473 (Fla. 1960) , this court held constitutional t e
to a claim arising before its passage, of a 1953 statute which
barred lairs against an. estate af`er three years. In H. F.
L.
.. - -- Realty
on •J. 7.irtlev 74 Sc.2d 175 (Fla. 1954) , this
-e application cf a twenty-
year upheld the constitutionality .._ ....
-� after
mortgages on a given data a er
year statute of limitations -� - -
one year f_-..• such
:en date on the ground that a reasonable
time is provided for the en'^--ement of a cause of action before
the restriction becomes effective. See Suck 7. Triplett, 32 Sc.2d
753, 754-55 (Fla. 134 were the court said:
"We are committedrule the that statutes
of this nature :statute ofy
limitation] are
good where _ reasonable time is allowed to
prosecute an asserted right."
and Cam=bell v. Horne, 3 Sc.2d 125. 126 (Fla. 1941) where the
court said:
"The law is well settled by decisions of the
Supreme Court of the United States and in
other =ur_sdi._-cis, that statutes of
limitation a--'• existing_ rights are
not unconstitutional if a reasonable time
is given for t.-.e en__ oe-•.ent of the right
be' --- she bar takes e".
The city contends that the application cf the Act
to
bar its claim violates the due process clause of the Fourteenth
:Az;ettdmeat to the Consti`.•-' .. of the United States.
Although it is a most important limitation on state
.action, due process has never been an absolute prohibition
g property rights.
against state legislation adversely _.l 3L:dCtln
It has been. held over and over again that genera: limitations
on state action do not extinguish the state ' s police pcwcr to
enact legislation "reasonably necessary to secure the health,
safet
y, good order, comfort cr general welfare of the community."
Sr_r Atlantic Coast Line Railroad •i. Goldsboro, 232 U.S. 543, 5=3
(1914),
5
•
;s'f'.5 - �_4w::fit u:% - •zL:t,i�:4- • i�,'i;:;', '. h;t;,i:'S, �.a. '�i:"� =,:zkv's- ur .c ri"°`sue' "..}:..;i:�;:.=N'II in deterfiAinc wh_toef state action Violated due ue
tiidedd prinCipled, a .curt must choose y. protectin
m.
g the
—
welfare of
_ :'<1�✓;_gi;;;,:�4�,,.y;_,�u� {,:• - I a e rights one hand and the
°r-�.:,Fya,�•-,:,.::�r;;it=%�',.,.r�`�r�:;,�:;.;r�' : "dual a guaranteed ri, _� on
��1�Ltt�` '+�' �!li i:?3i:• M
This me �. yy.cd cf determining
ma the general public en the other.
-'..1'::.ac,, j� r)?a"-i •c';" 2'iwai:;" Whether a state meets
etS the requirements of due process is
mm
called
o
the "balancing ,.. interest" terest " test.,^,, See S1es 7 : lcr, The
ME
nImerevement of envevanc:.by .c _s's. •I
= The Marketable Record Title Act,
designed
red to simplify
a .. a.
er stabilize titles and live certainty
flt,;x,.f�,z COnVeYanCeS of real property, � 1-' ,C:
to land ownership, is certainly legislation coteerning the wel-
fare .-, QuincyRailroad
"r',,.;9`�rtf,;: ti_it�;_ _ .•,.`.iPs,c. �-if% - the public. Cps Chicace ... L:.. _i. ..:1 Y
o� .,a_C
C592 19 5) .
� J 2 .J'l l:. r. 551, _
mmm
i�i�i �•`ti% :..fit.-::j'`1i�1�,:i'.N _ __ Company .. �i__.::ei I 0
The eity contends, hcwever, that the retroactive
nature
of the Act makes it an a-'^: `..any and unreasonable exercise of
police power. But ret_Cact_:e statutes have been almost univer-
sally declared cons` ""y ^sal when a reasonable time was given to
protect property interests by c='pl: ng with the new requirements.
Atchafalaya Land Co. v. F. B. Williams Cypress Co., 258 U.S. 284
(1922); Wheeler •7. Jac::3cn, 137 G.S. 245 (1890); Vance .. Vance,
108 J.S. 514 (1383).
Thus, the ccr.anal cb=e^"-n that retroactive
application of a statute results in a depri'7at-cn of due process
is cb:'sated where the statute gives owners of old_ claims Still
enforceable at the time of the statutory enactment a reascnable
time to take certain steps tr. preserve their interests.
E'er example, in Vance v. Vance, supra, the ccnstitl:ticn
of Louisiana was amended in April, 1858, to provide that "the
tacit mertgaces and privileges new existing in _rue state shall
.cease to have effect against third persons after the first of
January, 1873, unless duly recorded." Despite the retractive
effect of the statute in barring property rights conveyed prior
to the enactment of the statute, the court held that the statute •
limataticn affecting these existing rights was ccr.stitut-anal.
The court reasoned that such retroactive application was not
prohibited by the due process clause of the Fourteenth Amendment
6
iiiiuiii ■ii.i.
0
•
because areaschable Lire °nag given for the enforceent Of the
'dtion before the bar took place.
Indeed, in Wicheltan v. Messner, supra, the
Minnesota Marketable Record Title Act was attacked on the fiery
ground that its retroactive features violated due process of lbw:
In upholding the Minnesota Act as a proper retroactive recording
act the Supreme Court of Minnesota held:
"The recordation provisions of the act
provide for a simple and easy method by
which the owner f an ex . existing „_ interest
preserve presere it. If he fails to take the
step of filing the notice as provided, he
has himself to blame if his interest is
extinguished. The cons"---4onality
duty of
have
would seem to
imposing _n�� been settled pe•.tnd question by the _C
decisions sustaining retroactive recur±- yn
statutes. Scurlock, Retroactive is
Affecting Interest In :.and, Mich. :.ecai
Studies, ✓i- taas:.. .. ho `•
on, su a
33 :1.:1.:.dam 517.
have similar upheld tha validity of the Iowa
':'so Iowa cases _ � '
Marketable Record Title ,act as against the same _round of attack.
1..Y LaneTraveler's IIns . C.o. , sutra.
T�sdel .. Hanes,tea.. s:.__ V.
We are ••---• .. not confronted with the question of whether
the Marketable Record Title Act can be u~. , "'' `o divest the
.i.can
, people of the State cf
Florida of sovereign lands held in public
trust for them. This case is not similar to Cd-m ':. Cel__na
Co -oration, 241 41 Sc.21 977 (:la. 1977), where the Trustees of
theInternal Improvement Fund without any notice to the :u✓1ic
conveyed certain properties. In the case sub -e, the
Legislature :id -.ct lcse control rol of lands "irrevocably • ested"
in the trustees, :es Internal ' prc•: e:^cn _ Fund v. Root,
59 Fla. 648, 51 So. 535 (1910), so the grant to -
he city was
effective. The validity of Chapter 8205, Special Acts �-
1919,
hasbeen reccgn_:ed by the Trustees of the Internal Improvemen
t
Fund. Trustees �: -.:rcvement Fund v. Clauahtcn, 96
• Sc.''d 775, 7E5 (1956) .
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the Spediai ?dt q anted to the City "for ;tunidiPai
rui' Poses ofily" all of the state's "tight, title and interest
insofar as the same can be granted, to all submerged lands
including waterfront and riparian rights." The prevision that
the grant was "for municipal purposes only" was not a reservation
or exception, as nothing was severed prom that which
was granted.
See City cf Jacksonville v. Shaffer, 107 Fla. 567, 144 So. 888
(1932) . This .. , �visi-is a restriction cn the use of the
prcperty and ..ces not fall within the categcrl cf true ease —
;tents. See Mccre .. Stevens, 90 Fla. 979, 106 Sc. 901, 43 Ai.R
1127 (1925).
We next consider the cuestisn of whether the Marketable
ReccrdTitleAct applies so as to bar claims of title in the
e
'subject property where it was previously held in public trust
by the state, but later conveyed to the city. The city contends
ahat certain e:+:e_t .cns _n _ lcrida Statutes, Section 7 -2 • `994 ,
prevent the applicaticr. cf the Marketable Reccrd Title Act to
the city's claim. This statute reads as fcl_cw's:
"Subject to the matters stated in 5712:03,
such marketable reccrd� title be fee
tite s-
r
and clear of all estates, interests, Claims
or charges what3Ce:'er, the existence of
which depends pcn any act,'title t_ansacticn,
event or smissisn that occurred prior ts the
effective date _f the rcct cf title. Ali
such estates, interests, claims sr charges,
hcwever dencninated.whether such estates,
interests, claims sr :charges are sr appear
to be held cr asserted by a perscr, sui j'.:ris
or under a disability, whether such person
is within or withcut the state, whether such
perscn is natural cr ccrcorate, cr is
private or gc•:er... ental are hereby declared
to be null and void, -:;cert that this chatter
shall not he deemed tC a: sect a. " -
• .- -r _n e .n: _-.. 'States ,
Flc.._.:a cr env of _ s r._.___s, ocar:S
ccr.,..,_sZ_.ns or stner acenc:es __ser':ea in
the catent cr geed tv .:n:-.. tne ..allot
States, . icr_da cr _ ..
- its ace__es
parted witn title. (emphasis supplied).
•iii■uii11i111ii1iii iuiiiiiiiimmii
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The city says that it is an agency of the State of
EI'orida ehd thereby stands in the place of the state. The
anguage of this section discloses a sharp distinction between
the 'rights of the state and those of municipalities. under this
Section a reservation of an "interest in the state" is protected
when expressly set forth in a conveyance from the state. The
interest of a municipality is the same as that of any ether
extinguished by peration of the Act. The
person and may be e.; -
term agency (as contained in this section) does not include
Municipalities for Section 712.01(1) Florida Statutes, defining
terms used in the act, contains the following:
"The term 'person' as used herein denotes
singular cr plural, natural cr corporate_,
private or governmental, including the
state and any political subdivision or
agency thereof as the context for the use
thereof requires sr denotes.
The city argues that its claim was not barred by the
Title Act because the root of title relied on
Marketable Recb�..Joe (i.e.,the deedcm Florida East Coast Hotel
by St.�., it --
Corporation) is a wild deed. St. Joe counters with the argument
crat_cr. acquired " -
p
that Florida East ..cast Hotel Corer; the-^.-e, St. Jce's _ of
conveyance o__ =:�Henry M F 1ac'-
•'
title was not a wild deed. St. :ce __-_es u;en Marsha__ ,.
i?cl'dcod., where Atlantic Beach Corporation, with
: , Inc., sutra, � .,._..
Marshall as majority -
stockholder, acquired title to the real
proper...-.�_..�:ers; in 1913. in 1924 a forged deed -ported
property In
conveythe same proper to defendant's predecessors. The
to con•. --
claimed under a 1931 feed. The
defendant, Hollywood,�Inc.,
had remained wild, unimproved, and vacant. -- was
disputed -a^.� .. re.T,3:... '�tl .., _.._ - _,.
held that the trial court properly dismissed the complaint.
Although the deed initiating the chain of title under which
defendant claimed was forged and void, this deed formed but one
link in the chain predating the effective rcot of title. The
Appeal •.'. HC . vwcCd. Inc., sL ra, )
District Court of (:'!3r5h31. - - "•
affirmed the judgment dismissing the complaint with prejudice and
f tothis court as being one which passed
certified its decis�cr. _s
9
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::f 6nA duestioh of great public inteiest. We app£oVed the addition
the distfidt Court of Appeal, saying:
":,.Claims arising cut of transactions,
Whether based upon forgeries cr not, pre=
title are
dating the effective roots � ^f
extinguished by operation of the Act
unless claimants can come in under any
Of the specified exceptions to the Act.
In this case, petitioner fails.to_
qualify under any of the exceptions to
the Act, and, therefore, petitioner's
claims are barred.
"4. The certified question involved in
this was, in effect, whether the
eMarketable Record Titles to Real Property
Act, Ch. 712, F.S. confers marketability
to�a chain of title
_tle arising out or a
forged or wilddeed, sc long as the strict
requirements of the Act are met. This
question is answered in the affirmative."
Mar_==::all .. Hollywood, Inc., 236 Sc2d 114, 120.
In Whalev v. Wotring, 220 So.2d 177 (Fla. 1st DCA 1969),
,plaintiff's chain of title was based on his predecessor's 1908
deed, while defendant's _cot of title was a land patent issued in
1397. The court ap^"he Marketable Record Title Act and held
that the patentee's heirs were precluded from asserting whatever
claim, if any, they had under the 1397 land patent, since the
1903 deed in plaintiff's chain of title had been cn record for
more than thirty years. The court in its opinicn said:
t
"The purpose of Chapter 71Florida Statutes,
.,S.A., the Marketable Record Tile Act, is
to marketable eestate in land
recorded � for thirty•'earsormore and to
make same free and clear of any interest
transaction,
arising from a titleact, event,
.c she
e emission
date which
^occurred
oftherootcofrior title. the
effective
of Title' is defined as the last title
transaction recorded at least thirty years.
All interest arising prior to root of title
is declared null and void unless such
interest falls witnin r_n' of _hose classes
specifically excepted.By legislative
declaration, thisact is to be literally
construed to effect the purpose of simpli-
fying and facilitating land title trans-
actionsfacilitating by allowing persons to rely upon a
deed recorded for a period of thirty years
or more. The Act contains a provision for
protecting these claims which it would
extinguish." 220 Sc.2d at 191.
In Wilson v. Kelley, 226 So.2d 123 (Fla. 2d DCA 1969),
the plaintiffs contended that an instrument could not qualify
as a scot of title within the contemplation of the Act unless
it constitutes part of the chain of title emanating from the
p
'sovereign. In rejecting this contention the court said:
In
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•
°+,,:To hold as suggested by plaintiffs would
fust±ate the Act's intended beneficial
a€facts; and the Act's utility Mould largely
be Confined to the elimination of ancient
use restrictions and to the curing of formal
irregularities,function already performed
a
by other statutes and usually more quickly
title than the marketable -le act.
uThe 4 as a marketable
...table title act, is not
Concerned with the :ualit; of the
title
Conveyed by the _act of title so long as
the root purports to convey the estate
Claimed. Thiscan be :O even though a deed
is not cart of the chain of emanating
from the sovereign and is -:ere=tree often
called a.n 'interloping' cr'wild deed.It
can, uncle,. the marketable title acts, form
a root of title which may eventually cut
off the interest of a terscn who might
otherwise have a :lain. Therefore, a
..
Marketable title act Can re a _n
the chain cf "_• if the break is suffi-
ciently old." 226 So.2d at 127.
Unquestionably the deed _....m Flagier tc Florida
oast Hotel Corporation was a wild deed. The effective root
titledeed- Floridaast Coast Hotel Corporation
was the da
Paper Company cr..:anuary 10, 1344, and the wild deed
St. Joe nk hairs commencing before the effective
was merely a link =a 3 c - "`
title. The claim the citywould be barre
d under the
root of �_
v:. Hcl1 :wood°, Inc., supra.
reasoning in Marshall .
Howe•: er , the city says that Florida East Coast Hotel
Corporation did net have title to the submerged -ands. The city
argues that the conveyance n:eya nce of 14 acres "together with all and
singular, the _-rarer..•, rights and submerged _ands appertaining
thereto" was ineffective sc
than nothing more the i.."-'• '4 acres.
lion held reecrd tit__ to - '
To say ctherh_se, the city contends, would result in Florida East
Hot ' per3-ien holding tie by a wild deed to the
Coast__ C:,_, �-•
Atlantic Ocean ~bottom. St. JCe contends that this is immaterial,
for the deed from Florida East Coast Hotel Corporation to St. .:ce
:t the _cot title even
on January 10, 1944, could constitute �- -�
though this conveyance may be classified as a wild deed.
Florida
East Coast Hotel Corporation bulaheaded and filled a portion cf
the property in question in 1320, but left a yacht basin. The
conveyed all cf the lands involved and, after
deed to 3t. Joe co.^.•:e; _ _..
1944, St. Joe :i11ed and bu::headed the yacht basin. We are
East
of
to
that Florida
11
East
Coast Hotel pera-
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.irt.'��t' ':ice:'L•t:S.»^�`Ltt.��.r�.
ked td hold; without equivocation, that A wild deed stay dohstie
$iti a toot of title. We so hold:
the city argues that a wild deed is void and passes
ho interest whatsoever in the land. This being so, the city
Contends that a wild deed cannot be the Foundation for a vested
estate that would fall under the protection of the Act. The
ere be a "root of title" : t
city states that the Act recuir=_s that t
which involves a "title transaction." A "title transaction" is
defined by Flcrida Statutes, Section 712.01(3) as one which
Affects title. The city contends that a wild deed does not
affect title.
This court, as well as the First, Second and Fourth
District Courts of Appeal have made it clear that the Marketable
Reccrd Title Act deviates from common law and prier statutes
and, by dicta, have said that a wild deed, properly executed and
recorded, may establish a new and valid ._.le after 30 years.
Marshall v. Ecile wood, supra: Whale, 7. ,•ior___. supra, Wilson.
v. Kelley, su
This court in I' _ Ra';cnie , Inc., v. ,:adswcrt:'., 346
So.2d 1004 (Fla. 1977) rejected the argument that only a valid
deed could act as a root of title. In this decision the terms
"n.cot of title" and 'title transaction" were ccnstrued as
follows:
"...:tthedeed'purports'
should be cb<:ices that purper
to create or transfer an estate. Purport is
defined in Webster's 3d New International Dic-
tionary unabridged (1962,?as'profess outwardly:
have the often specious appearance of being.
Certainly the Lecisloture intended the word
'purport' to have its accepted meaning. The 1937
deed meets that meaninc.
"The deed 'a "e s title' and, in turn, is a
title transaction as _hose terms have been con-
struedMarshall Hollywood,str::e�di:: Florida.: Ci In .:r _ •: He • _
Inc. 224 So.2d 743 (Fla. 4th -CA 9' ), the
Fourth Di- r -- Court, speaking throuch Judge
Reed, stated at =ace 749:
'The word "affecting' as it is used in
the second sentence of Section 712.02
in the clause "aff acting the title to
the lend" :Cris not carry the narrow
mean_nc of "changing =r altering". The
word is used in the hrsader sense
meaning "concerning" or "producing an
effect upon". In this bread sense,
even a void instrement of reccrd
"affects" land titles by casting a
cloud or doubt thereon. Clements v.
12
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•
Ie^3ersoii, ].315, 70 1a• i60, 70 4o: 439.
aroWn,.v_: Salary, 1396, 37 -la, 102, 19 So,
161',' 346 So.2d at 1010.
th this case it appeared that Wadsworth, Sr,, died
h 120,16 possessed of homestead property and survived by his
'.'Widcw and four children. The statute Governing the descent of
homestead provided that the surviving spouse wculd receive a
life estate in the hcmestead - seer_- subject to tested re-
_
nainders in any children. In 1937 s. :Zadswcrth , the survivingldr•'o'r
conveying the entire fee simple her..
spouse, executed a deed .. _ _ __ .. -
ln 1942 Mrs. Wadsworth
Selz. and her son as tenants _.,.._..^n. In
and her scn conveyed the pert- -
to Raycr,ier. Rat •,_er claimed
_: _
a Marketable Reccrd Title free and clear of the children's
vested remainder since that interest arose prior to the 1?37
mot of title.
The children argued that Florida Statutes, Section
712.02(1) preserves estates, interests, easements, and use
restrictions _ _ and
defects inherent in the muniments
of title cn which the estate is based, beginning with the root
cf ''''' The children said that this statute preserved their
interest hecause the 1927
deed had twc inherent defects: 1)
+•e•-�G�property
__ �... •,:n�:eC the:_ remainder1.• a: , ^-1 .... .�� _•e.yed
from Mrs. Wadsworth c These arguments were :ejected
because ^� term inherent in the muniments
of title"
do not -n= _ to defects cr failures in the transmission of
title, but refer to defects in the makeup or co.•____ •• .,f
-he trans . ission cf title depends. The
the doe,? or. which_
G.' t •..-an Sarg=ents were geared tc def''r-= 4n the __ _••Z..._saicn
and there was netting on
the face of the deed to indicate that
it ccn. dye d the ch__dren's remainder interest,
were nct saved from extinguishment.
The 1944 deed to St. Jce purported
so those interests
tc create an estate
and •°'ed as a "rcot of title." The city gains no help from
the , _pyiaiCh3 OfFlorida
` FlorStatutes, Section 712.03(1) because
_her_ was nothing er• the face sf the deed indicate _cat.
`;$ye'". a..,. -pot Of the city. This ccurt made it clear
13
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flficia Statute„ section 12:03(1) refers only to defects
makeup Of the deed when we said:
"Section 712.03, Florida Statutes, provides
that marketable record title will not ex-
tinguish six categories of rights that pre-
date the root of title. The first of them,
four in subsection (1), is 'estates or
int-:rests, easements and use restrictions
tie, d -es s inherent in the
disclosed a.^.� seer
Muniments of title cn which said estate is
based beginning :with the root fir title.'
The children argue that
in-e`.=` are within the - first cateccr•.
because the 1917 .heed hastwoInherent
defects: (1; itc :eyed their remainder
interests and (2)vit conveyed property
from .,,eta to her_se.f. The phrasing of
their argument shows a misunderstanding
f ^e statute. As the Fourth District
C
Court _f Appeal - Appeal stated in Marshall:
h- terms �-
the_-en'defects
tsof'c_t_e' do'not refer
n .,r s the trans-
mission Defects or f - i••
cn of t_ as the plaintiffs
m 1 J J i title, _ I argument suggest -a, tut refer to
defects in the make up cr consti-
tutionment-oc- _ ,,e` deed which suchr Tuni-
trans-
cn depends." 224 5o•2d at 751.
trans-
mission
"The __ r the deed ces not reflect the
dThectyof a conveyance from Lotto to herself."
ITT ve , .. adsworth, supra at 1010.
The ??r.t deed to St. .,ce does net reflect that it was
wild deed ncr ..ces it appear that _here is any cef ect in the
the de- This deed may properly cons`. " a
makeup of ,. _... _ properly
of `'-'
s
iies that the Marketable Record
The city 3150 ••�+
Title not operates
rates as a means whereby peep' -
a can steal land.
Florida Statutes, Section 2.01(6) excepts the rights cE any
person in whose ....me the la nd !'as beer. assessed cr. count: tax
-
This section of the statute
:Dies _,._ a :er_cd __ three years.
requires that owners of land pay their taxes and by doing so,
would stop any party frsm pirating their land. Moreover, an
:.
interest in land can be , reset Jed by any party by riling
withinnotice the 30-year period subsequent to the root of title
in accord
ance with Section 712.05, Florida Statutes.
The coert in ,ailson v. al y, supra, also noted the
�- prevent an int_rlcpi - deed from -"t` ng
safe^:...rd� wni_.. would - •_ -
14
aneith?r ?erso n't deter-:inci interest ih td1J5 'of a utideter'Ji c
A,schf in this as the court said:
"For those who are concerned with the ii:elihtod
that the Act will allow an interloping deed to
cut off another perscn's deserving interest in
favor of an undeser•._ho person, there are safe, -
guards in the Act to
prevent this from happening.
A claimant will not be cut off if he has been a
patty to any `; ' transaction ro---ded with_., a
period of not less than thirty Mars cr if he
files a simple notice rescr hed by the Act
during the time allowed for this purpose. e
will not be cut
_f if he remains in possession
or if the lens is assessed to him on the tax
roll. given if it Is no _pager assessed to him
he is prVtom- .,= if it was assessed to him at
any time�
during the precedingthree ;ears. But
if he has beena car to notitle transaction
recorder for at least thirty years durin
g which
time he has also f-___d tc file the notice, and if for more than three :ears he has allowed the
be assessed _:_ taxation someone else,
land to - - under
andif neither he noranyperson _aims. _nd
possession ofthe land, it wouldnet
him is in i
seem un:ust
that his claim should he subordinate
tc anotherperson's claim that is based upon a
chain of title going back to an instrument or
court proceeding has been recorded at least
thirtyears, and that epur7orts to create or
transfer th
e estate' claimed _ the second person.
' Inthe public into -opt cfsimplifying and facil-
itating land title nsact_ons, it does not seen
unreasonable
for the legislature to
..
presumption one who is negligent in claiming
his land has abandoned his claim. 225 Sc.2d at 127.
+.e poi cut that the -.:es: of whether
In summary .._ question
the M rketable Record .___e Act ca.. he utilised to divest the
a _
State cf sovereignlan
d is not considered,considered,as it is not an issue
in the case. By this opi.._.... we Rol...
1) The Marketable Record Title Act is ccns• ""` enal;
2) The city is not an agency of the stare and does
ace of the statethe application of the
.act stand in theplace in -
provisions of the Marketable Record Title act;
title.
3) A wild or interloping deed may const""•'e a root
The decision of the District Court of Appeal, as well
.as the opinion expressing the views of the court, are approved.
The writ of certiorari is discharged.
��. BERG MATCF:E_. and AL:E . ..N, ,;.; . ,
::G:.A::D, C.J. , EOYD, 0� Ca, i.:iC ,
Coheir
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in the
3upreme Qltrnrt of ±Rtotila
CASE NO.51 ,775
CITY OF MIAMI,
a Florida municipal corporation..
Petitioner,
Us.
ST. JOE PAPER COMPANY, a Florida corporation;
SOUTHEAST PROPERTIES, INC., a Florida corpora-
tion, HUGH E. MATHESON, JR., individually; and
SALLY S. DOMMERICH, formerly Sally S. Matheson,
individually,
Respondents.
PETITIONER'S BRIEF IN
RESPONSE TO AMICI CURIAE
1111111111
1111
BAILEY & DAWES,
a professional association
Attorneys for Petitioner
Suite 1820, One Biscayne Tower
Two South Biscayne Boulevard
Miami, Florida 331:31
0
1
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TABLE OF CONTENTS
Page
INDEX OF AUTHORITIES ii
INTRODUCTION
QUESTION PRESENTED.. ....... 4
ARGUMENT _.._.._..._. 5.
THE LAND IN DISPUTE IS SOVEREIGNTY
LAND 5-
A. Sovereignty Land Is Held in Trust For
The People
B. Illegally Filled Land Retains its
Nature
Sovereignty N
C. Sovereignty Land Conveyed To The
City Retains Its Sovereignty Nature - 9
D. Sovereignty Lands Cannot Be
Divested By A Wild Deecl 12
CONCLUSION
CERTIFICATE OF SERVICE 18
111pl'IIIII
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I ! 111 11 1
111
'IIIIII'
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INDEX OF AUTHORITIES
Case Page
Allied Structural Steel Co. c. Spannaus,
98S.Ct .2716(1978) 13. W.
County of Orange c. Heim,
106 Cal. Rptr. 825.30 Cal.App.:3d -
894 (197:3)
Haves c. Bowman.
91 So.2d 795 ( Fla. 1957) .............
In Re East Ricer Drice, Borough of Manhattan
289 N.Y.S. 4:3:1 (19:3E3). aff"d.
21 N.Y.S.2d 507 (1937 )
International Paper Co. c. Miss. St. Hwy. Dept.,
271 Sn.2d :395 (Miss. 1973). cert denied.
114 U.S. 827
Martin L. Busch.
9:3 Fla. 5:15. 112 So. 27.1(19271
Odom c. lleltona Corp..
:141 S►.2d 977 (Fla. 1977)
Pembroke r. Peninsular Terminal
108 Fla. -}Ei. 146 S1. 249 (19:33) ..
People c. Hecker.
1 Cal. Rptr. 334 (1960)
1111111111111
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Case
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III
I
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414
INDEX OF AUTHORITIES (Continued)
People c. Poceromo,
:159N.Y.S.2d8-18(197:bi .........._
People. Town of Smithtown u: Iliwerarnm
3:36 N. V.S.2d 764 (197D, ...
State ex rel. Ellis c. Gerbing.
5E; Fla. 60:3. 47 So.:353 (1908) _.
Thiesen t'. Gulf F&A Ry.
75 Fla. 28, 78 So. 491 (19IS)= ...
Twomhley c. City of Long Bead
:33:3 F.2d 685 (9th Cir. 1964), cert..
denied. 85 S.Ct. 195 ( 19E3•1) ............
United States c. 2,899.17 Acres of Land,. Etc.,
269 F.Supp. 90:3 ( N1.D. Fla. 1967)
United States c. State of California,
381 U.S. 139. 85 S.Ct. 1401,
14 L.Ed.2d 260 (1965)
United States Trust Co. of New York srt
New Jersey.
97 S.Ct. 1505 (1977) _..
to
II
li
12
6
114
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INDEX OF AUTHORITIES (Continued)
Case
Other Authorities
Butler Act
Florida Statutes Chapter 712,
United States Constitution, Contracts
Clause. Article I, Section 10. Clause 1 .....
Page
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in the
§upreinr 1tnurt of floribn
CASE NO. 51,775
CITY OF MIIANII,
a Florida municipal corporation..
Petitioner.
c' 5.
ST. -JOE PAPER COMPANY. a Florida corporation:
SOUTHEAST PROPERTIES. INC., a Florida corpora-
tion. HUGH E. NIA'I'HESON. •JR.. individually: and
SALLY S. I)OMI\IERICH. formerly Sally S. Matheson.
in(livido�illy.
Respondents.
PETITIONER'S BRIEF IN
RESPONSE TO AMICI CURIAE
INTRODUCTION
Months after oral argument in this cause, two,
amicus briefs have been tiled — one by the Governor
and the Attorney General of Florida, another by the
phosphate industry.
IIIII
111111111
Bath ague this Court's holding in Odorn v. I)eltona
Corp.. :311 S0.2(1 977 ( Fla. 1977). and the effect of the
197S amendment to Chapter 712 (the Marketable
Record Titles Act ). The State argues that Odom was in-
correctly decided. and. alternatively. that the 1978
amendment changes the result reached in Odour. The
phosphate industry predictably disagrees.
But the argument as to Odom ;s continuing validity
is not relevant to this appeal. For the Odom opinion
makes clear its inapplicability to this rase. Odom holds
that. when the State conveys land which is not
noticeably naci:;able to private citizens without reserva-
tion of public rights. Chapter 712 applies. Mr. Justice
Boyd, writing for the Court. noted that the result would
1)e different "in the case of a large lake. such as Lake
Okeechobee." Odom )hakes clear that government
ownership of such land is not extinguished by Chapter
712.
Respondents have continually urged this Court to
misread its own holding in Odom. arguing that because
the State conveyed the land to the City in 1919 and St.
Joe then took a wild. void deed to the same land in 1944.
the City in 1975 could not quiet title. Odom does not
support this. Odom would he apt here only if the City
ow the State) had purported to convey this property in
1944 to private grantees. Had that happened (and. of
course. it did not ) Odom 's gloss on Chapter 712 might
preclude this suit. But even this rule would he subject to
the critical exception of notice of nauigohilitY.
studiously ignored by the Respondents. and apparently
not even perceived by the writers of the amicus briefs.
410
Odom makes clear that Chapter 712 dos not apply
to this action. There has been no conveyance to private
grantees of this property, and the Respondents are
charged with notice of the obvious navigability of
Biscayne Bay and the Atlantic Ocean.
The State, properly concerned about Chapter i 12 s
applicability to sovereignty lands. and not aware that
Odom compellingly supports the City's appeal. bases its
eat ire brief on the unsupported and in fact insupport-
able statement that the land in dispute in this case is
not sovereignty land. This attempt to whistle past the
graveyard is completely contrary to all applicable law.
■
HEI E I1l!IIIII
IIIII
111IIIIu■I■I -I
QUESTION PRESENTED
WHETHER TI-IE LAND IN DISPUTE IS
SOVEREIGNTY LAND
41,0
ARGUMENT
THE LAND IN DISPUTE IS SOVEREIGNTY
LAND
A. Sovereignty Land Is Held In Trust For The
People
B. Illegally Filled Land Retains Its
Sovereignty Nature
C. Sovereignty Land Conveyed To> The City
Retains Its Sovereignty Nature
D. Sovereignty Land Cannot Be Divested By,
A Wild Deed
The Land In Dispute Is Sovereignty Land
A. Sovereignty Land 1s Held In Trust For The People
The (public trust doctrine «'a!, created not for the
Protect um of the State, but for t ile protection of the peo-
ple. Accordingly. the courts have refused to allow the
State to abdicate its deities as trustee.
In Florida. this has meant that the State can convey
the waters. shores. and beds of navigable waters to
private grantees only after statutory notice and public
hearing and a studied conclusion by the Trustees of the
Internal Improvement Fund that a grant of a limited
portion of sovereignty lands will not harm the people of
Florida. And even then. the State retains the right and
duty of control and regulation. A putative conveyance of
I,1I1III
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sovereign'' lands not meeting these stringent require-
ments will he held void by the courts. unites' States v.
2.899.17 :Acres of Land, Etc., 269 I:.Supp. 9ft . 908 ( I.D.
Fla. 1967) ("If. by mistake or otherwise. sales or con-
veyances are made by the 'Trustees of the Internal Im-
provement Fund of sovereignty lands . . . such sales
and ('nnveyall('t's are ineffectual. . . I. See generally
Haves t'. Bol(•rnan. 91 Sn.2d 795 ( Fla. 195 ): Pembroke
u. Peninsular Terminal Co., 1(18 Fla. .16. 1.1(i So. 2.19
( 19:;3)::llnrtin r. Busch. 9:; Fla.:t:;5. 112 So. 27-1 (192'i ):
Thiesen t'. Gulf F&A Rv. C'o., 5 Fla. 2S, S So. 491
( 1:r1,`;►: State ex rel. Ellis t'. (1erbinti, :16 Fla. 603. 47 So.
:;:,:i ( 19(1,S).
In Odom, this Court considered the effect of Chap-
ter 712 on this established case law. Noting the frequent
difficulty of determining factually what is or is not
navigable water and sovereignty land. the Court held
that where the State had conveyed land, thereby mak-
ing a contemporaneous factual finding that the land was
not sorererj.,,rl, and the surface water on the land was in
fact not noticeably navigable. Chapter 712 precluded
the Mate from later asserting that the land was
sovereign and its conveyance invalid.
The Attorney General's assumption that the land in
the instant case has somehow ..lost.. its sovereignty is an
unwarranted andication of the public trust and contrary
to all applicable judicial authority. The land is
sovereignty land. vested in the City. and Chapter 712
does not and cannot apply.
11111111111111111111
II
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II
11111111
B. Illegally Filled Land Retains Its Sovereignty
Nature
The land in dispute was illegally filled — this fact
has never even been disputed in this appeal.
As any good faith title searcher would have found, in
1944 (the date of St. •Joe's wild deed). the grantor had no
title, nor even a colorable title, to the City's land. In
1919. the date t he conveyance to t he City, the riparian
rights act nt 185(; did give rights to certain riparian
landowners to dredge, fill. and bulkhead, and thereby to
acquire title -- but only to owners of land to the lots
Crater mark. Hayes C. Bowman. 91 So.2d 195( Fla. 195 i l :
Thiesen r. Gulf F&A Rv. Co.. 75 Fla. 2S, 78 So. 491
( 1918). St. -Joe's putative predecessors in title owned
only to the high water mark. In 1919, the submerged
lands were vested in the City. Any tilling subsequent to
this was totally devoid of legal authority. Moreover.
even it' FEC had owned title to the low water mark. the
riparian rights act itself would have authorized filling
only to the channel. And all of the disputed property is
nut side of t he channel.
Therefore. the land in dispute did not lose its
sovereignty nature by the unlawful filling. A public trust
cannot he divested by sheer theft. According to time-
honored property law, artificial fill belongs to the owner
of the stihmerged lands — in this case, the City. in trust
for the people.
In United States v. State of California, :381 U.S.
139. 85 S.Ct. 1401, 14 L.Ed.2d 260 (1965), the federal
government challenged California's claim to certain
submerged lands contiguous to islands off the coast. The
■
Supreme ''Court held. that artificially filled land
belonged to the State — in its sovereignty capacity:
"IW1hen a state extends its laird domain by
pushing hack the tied . . . its sovel'('igllty
should extend to the new land.. .
l:181 U.S. at 1771
This same principal was followed in International -
Paper Co. v. Miss. St. Hwy. Dept.. 271 S().'_)d :195 (Miss.
197:11, cert. denied, 414 U.S. 827. The plaintiff in that
case challenged the state's ownership of tilled land.
Emphasizing the special characteristics of sovereignty
title. the court o►ncluded:
"ITIhese changing characteristics of the land
did not displace the trust imposed upon the
state for the public.'•
1271 So.'_)d 3991
In County of Orange c. Heim, MG Cal. Rptr. 82 .:1t1•`.
Cal.App.:1d 04 (197:1). the court held invalid a grant to
a private owner of artificially filled lands. The court;
reasoned that to held otherwise would impede the
county from tilling land to henetit the public.
The same conclusion was reached in People v.,
Hecker. 4 Cal. Rptr. :1:1.1.:14:1 (19011:
"IAIccretions . . . caused entirely by artificial
means . . . such as . . . the dumping of
material into the ocean — belong to the state.
or its grantee. and do not belong to the upland
owner...
8
411111.111111
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111111111111111111111111111111111111111=0
The State suggests that the applicahiti2-v of Chapter
112 to illegally tilled land should turn on the grantee's
notice of the illegality of the fill. Such an approach
might well be valid in cases such as Odom_ involving
land adjacent to N.vater which is not noticeably
navigable. Hut it is inapt to the facts of this appeal.
Fur when St. Joe took its wild deed in 19.4. it had
before it a deed purporting to grant lt0i9 acres more
than the grantor awned of record. The City has been
precluded by dismissal on the pleadings from engaging
in discovery to prove St. •Iue's actual notice. But St. Joe
is clearly charged with legal notice — of navigability. of
the sovereign nature ut the land, of the City's title, and
of the illegality ut the fill. Any good faith title searcher
would have discovered these facts.
The land in dispute therefore did not lose its
sovereignty nature by being illegally filled.
C .
Sovereignty Land Conveyed To The City Retains
Its Sovereignty Nature
In 1815, by act of Congress admitting Florida to the
Union. the United States conveyed to the State all right.
title, and interest in lands under navigable waters. and
within or about its shores. "in trust for the benefit of the
people of Florida.••
On June 2, 1919, by special act, Florida's
Legislature conveyed submerged lands to the City of
Miami, reserving its interest in having the sovereignty
lands remain public by imposing upon it the require-
ment that it he used, in perpetuity, for "municipal pur-
poses only...
9f
111
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i
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The : orney General. in his brief, assumes.
without either authority or analysis. that when the State
conveyed the property in dispute to the City. the
property "lost- its sovereignty nature. All the judicial
authority on this newly -raised point is directly contrary.
Sovereignty land conveyed to a municipality. as an
agent of the state. plainly retains its sovereignty nature.
The public interest in sovereignty land can he alienated
only when the State. expressly intending to do so. con-
cludes. after statutory notice and public hearing, that a
lilllited portion of sovereignty lands may he alienated
without harming the public interest. Otherwise. the
land retains its sovereignty — particularly where. as
here. the land is conveyed to the States agent. the City.
for municipal purposes only.
In the instant case, t he 1919 conveyance to t he City.
even had it not been expressed 1n the grant. carried with
it the limitation that the land was sovereign — imposed
with a trust for the benefit of the people of Florida. In
other words. the State could and did convey to the City
only what it had - sovereignty land indelibly imprinted
as "public.
The applicability of the public trust doctrine to
sovereignty lands conveyed by a state to a municipality
has been most recently clarified in a well -reasoned New
York decision. People, Town of Smithtown v. Poveromo.
:3:36 N.Y.S.2d 764, 769 (1972). aff •d on point cited but
remanded on other grounds sub nom People v.
Poveronto, 359 N.Y.S.2d 8481197:0:
i
111111i
"It therefore becomes apparent that no person
can become invested with absolute ownership
II,I
91
10
11111111111111iiiminum
11
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of these lands.. . . Whoever succeeds to the
sovereignty succeeds to that right of property
and holds it in trust for the nation. . . . .Onl
the 1Sth day of June, . . . the people of
the State of New York granted the land under
the \issectuogue to the Town of Sillithtown.
The rxtent of the conveyance was necessarily,
limited by the trust in favor of the people. the
dus Puhlicum. just as it affected the
proprietary ownership of the grantor state. The
people of t he State of New York clearly have an
interest in the enforcement of the trust in their
favor that is ingralted upon the ownership of
the Nissegiin ue. . . . The state can no more
abdicate its trust over property in which the
whole people are interested, like navigable
waters and soils under them, so as to leave
them entirely under the use and control of
private parties, except in the instance of par-
cels mentioned for the improvement of the
navigation and use of the waters, or when par-
cels can he disposed of without 1i11ptirment of
the public interest in what rcinains. than it can
abdicate its police powers in the administra-
tion of government and the preservation of the
peace.. .
l emphasis supplied l
Accord: In Re East River Drive, Borough of Manhattan,
289 N.Y.S. 4:33, 4:39 11936). aff •d, 21 N.Y.S.2d- 507
(19371:
"The courts have held time and again that the
title such as the city holds is in its sovereign
capacity,. and not in any proprietary capacity.-
11
i l"7■ i II 7
II
1!I1INP'1!'111111i111
II
ppII
11111111111
uIIuIO
i
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See also (. ntv of Oran, ' t•. Heim, 1(Hi Cal. Rptr. 82:1.
:;t► Cal.App.:3d 691 t 1S)7al ►sovereignty land conveyed to
county subject to public trust►.
The i'nitt•(t States Court of Appeals for the Ninth
Circuit has also held t hat sovereignty land conveyed to a
municipality retains its sovereignty nature. iu )rnhhy
t'. (it\ of Long Beach, :3:3:3 I:.2(1 N':) 19th ('ir. 196.1►. cert.
di'1►ir(i. ti:) S.t't . 1:). i l91i.1). In that case. a citizen and
taxpayer sued to enjoin the city from sharingu reve'iities
produced from submerged lands with t he state. The
state had conveyed the land to the city. viih a use
resiric'tl(tt1 to -establishment. improvement and con-
duct hal'1N,1' The trial court dismissed the com-
plaint. The Ninth Circuit affirmed. holding that the
land remained subject to the public trust. The United
States Supreme Court denied certiorari.
The State cannot, by legislation. inadvertence. or
otherwise. alienate sovereignty land in a manner incon-
sistent with the public trust. The 1919 conveyance by
the State to t he City of t he land in dispute. "for
municipal purposes only.- cannot be construed as a
divestiture 01 the public trust -- the State conveyed
only «hat it had sovereignty t it le. The land is
sovereignty land. the land belongs to t he City. and
('harrier 712 does not and cannot extinguish the City s
ownership.
D. Sovereignty Land Cannot Be Divested By A tVi1d
D('t'd
The Attorney General. in his attempt to whistle'.
past the gni\ eyard and avoid the public trust doctrine of
sovereignty lands. does correctly point out that other
12
1■1111 .■II.
issues of great public importance are presented by the
City's appeal. Each of those issues compel a reversal of
the courts below.
Chapter 712 does not. and cannot constitutionally.
validate St..1oe's wild deed. And Chapter 712 does not
apply to the Citv's title as an agency of the State.
As the City has previously argued, under the
Federal Contracts Clause. Article I, Section lu, Clause
1. of the United States Constitution. a state may not
retrospectively exercise the police power to extinguish
vested rights which in no way conflict with the public
interest.
When this argument was first presented. St. Joe
responded by saying that the Contracts Clause was
rarley invoked by Federal courts in limiting the powers
of the States. The [united States Supreme Court then
issued its opinion in United State, Trust Co. of Nett,
York c. New Jersey, 97 S.Ct. 1505(1977). making abun-
dantly clear that the Contracts Clause is far from a
"dead letter.'' That opinion is discussed in the ('ity's
Reply Brief.
The United States Supreme Court has subse-
quently struck another state statute as an un-
c oast ittitiotlal impairment of contract. Allied Structural
Steel Co. t'. Spannauti. 98 S.Ct. 2 i 11i (1978). The statute
challenged subjected certain private employers with
pension plans to a "pension funding charge" it' the plan
was terminated. The effect was a statutorily imposed
vesting requirement. The Court. in an opinion by Mr.
Justice Stewart. held that the statute failed con-
i
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MI
-1110
stitiitional r•utiny. The opinion is fatal to the lower
court's application of Chapter 712.
"In applying; these principles to the present
case. the first inquiry mist he whether the
state law has. in fact, operated as a substantial
impairment of a contractual relationship. The
severity t)t t he impairment Ineasur•es the height
of t he hurdle the state legislation must clear.
Severe i►npairment . . . will push the inquiry
to a careful examination of the mature and pur-
pose of the state legislation."
1 J S.Ct. at 272:11
Here. Chapt er 712 as int erpreted below ex-
tinguishes vested property rights in favor of a wild deed.
T1he statute in question here nullifies ex-
press terms of the company's contractual
t)hll:.'atit)ns and imposes a completely unex-
pected liability in potentially disabling
amounts. . . . Yet there is no showing in the
record before us that this severe disruption of
cont ral•lllal expect at ions was necessary to meet
an important general Social problem. The
presumption favoring 'legislative Judgment as
to the necessity and reasonableness of a par-
ticular measure. L'ntted .States Trust Co., -131
U.S.. at 23. `); S.Ct., at 1.)1S, simply cannot
stand in this case.•
1!),ti S.Ct. 2724, emphasis supplied,
The specialized and limited problems of title •
searches clearly do not warrant the "severe disruption"
1.1
II 1111111111111111111 INi 1111111111MINI
of divestiture of property. Chapter 712 as applied below
unconstitutionally impairs contractual rights.'
!Moreover. application of the Contracts Clause as required by
Allied might satisfy the State's apparently obsessive concern with
the validity of prier State transfers of submerged lands to private
parties under the Butler Act — those transfers as contracts by the
State ias well as the deeds in Odonm► might he protected by the
Contracts Clause. Respondents in this case. of course. have no such
protection, claiming title to the City's land by virtue of a wild. void
deed from a private grantor who had no colorable title.
15
Ummulig677-0111I I�IP .� I
11
1!1'11111u111111
p
11!
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i
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CONCLUSION
In 1919 Tlie Statf' of Florida conveyed to the ('ity of
`Iiaini the disputed land. as sovereignty land. The land
NVas then. and is now. held in trust for the people of
Florida.
The City as trustee cannot he and is not divested of
this land by Chapter 712.
The courts below have held this public land
divested on the basis of a void deed which was illegally
eXecuted by persons who were on legal as well as. in all
probability. actual) notice ul' the public trusteeship of
that land. In so doing, the courts below have ignored
Florida case law. have ignored the public trust. and have
imposed upon Chapter 712 an unconstitutionality so
pervasive 1 hat it runs afoul of almost every con-
stitutional protection accorded vested property rights.
Chapter 712 should he held inapplicable. and the
opinion below quashed.
igql,qI
Respectfully submitted.
BAILEY .l• DAWES,
a professional association
Attorneys for Petitioner
Suite 1820. One Biscayne Tower -
Two South Biscayne Boulevard
Nliaini, Florida :331:11
(:3O5) :37•1-5505
By:
Guy B. Bailey, Jr.
•
to
■uIiuIIIuI■II1uII
IIIII
11
I
IIIII
and
III IIII IIIIIIIII.■I
Ii,li gl�11
ICI
11
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the
foregoing Petitioner's Brief in Response to Atnici Curiae
.vas mailed to Shutts &. Bowen. ltltlt) Southeast First
National Hank Building. Miami. Florida :131:U: Sibley,
Gihlin & Levenson. l:1t)1 Dade Boulevard. ? iiatni
Beach. Florida :3:31:39: Steel. Hector & Davis. 14b0
Southeast First National Bank Building. Miami.
Florida :331:31: and Russo. Van Doren & Allen. P.A..
4685 Ponce de Leon Boulevard, Coral Gables. Florida
3'3146. this 12t h day of September, 1978.
OF COUNSEL
u
11111111011111111111
III
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« ! ,
.-,1:.; ; i •
• t• rf ' '
: • .'* t ; '-'. 1 i , . '
• ,I • , ,.. t t . . . . .
. .
. ..• , 1. 1 ' C. it.%4,%-.44..e.P614.ktittitir..,;;;.. ita,Zit. e. 4.,ar,I..;too.tt .r..ri.....tt.4--4‘.;it .i.,itTair.. ;Irk' t,;;:t.tr:...;it:ta,... ,it;
- in die 4
c (gaud of Martha
CASE NO. 5t,775
CITY OF MIAMI
a Florida municipal corporation,.
Petitioner.
VS.
ST. JOE PAPER COMPANY.
a Florida corporation:
SOUTHEAST PROPERTIES. INC.,
a Florida corporation:
IIUGH E. MATHESON, JR.. individually: and
SALLY S. DOMMERICH. formerly
Sally S. Matheson. individually.
Respondents.
PETITIONER'S REPLY BRIEF
LAW OFFICES
GUY B. BAILEY..111.
Attorneys for Petitioner
Suite 1820. One Biscayne Tower
Two South Biscayne Bouioard
Miami, Florida 3313 i
1
1111111111111111111011111110
CITATIONS OF AUTHORITIES
Case
Judicial Decisions
Honda
fllhury v. Central and Southern
Florida Hoot! Control District
99 So.2d 24 (3d Fla. DCA 1%5
Biltmore Pillage v. Royal
71 So.2d 727 (Fla. 1954)
Bradd t' ci Hale Fishery Co. v. Thomas
93 Fla. 326, 112 So. 55 (1927) ., ......
City of iami v. Benson
63 So.2d 916 ( Fla. 1953) .....
City of Miami v. St. Joe Paper Co: 1
347 So.2d 622 (3d Fla. DCA 19977) _ ..... .
Page
Geary v. Estate of Creary - 17
33S So.2d 26 (1st Fla. DCA 19j7Ca . - .
Ellis r. Brown
77 So.2d 845 (Fla. 1955) . .
Emhart Corporation v. Brantley
257 So.2d 273 (3d Fla. DCA. 1972
Gonzales v. City of Belle Glade
287 So.2d 669 (Fla. 1973):.
q u'I1I'!"II''I II
1Il
E1I'111!!p11.1t111!
P�!
111
11111,11111,1,1
1'1
11'
1
1,1111111
II
1,1111
h,!1II;1
■
i,
CITATIONS OF Al;TIIORITIES ;Continued)
Case
Haves v. Bowman
91 So.2d 795 (Fla. 1957)
ITT Ravonier. Inc. t'. Wadsworth _
346 So.2d 1004 (Fla. 1977) . .
In re Estate o/ .leffott
186 So.2d 80 (2d Fla. DCA 1966)
Je1lerson National Bank at Sunny Isles
v. Metro Dade County
271 So.2d 207 (3d Fla. DCA 1972) .. .
Johnson t'. State
178 So.2d 724 (2d Fla. DCA 1965) ......
Marshall v. Hollywood. Inc.
224 So. 2d 743 (4th Fla. DCA 1969),
aft'd, 236 So.2d 114 (Fla. 1970)
McCord v. Smith
43 So.2d 704 (Fla. 1950)
Odom v. Deltona Corporation
341 So.2d 977 (Fla. 1977) .....
Overstreet v. Bishop
343 So.2d 958 (1st Fla. DCA 1977)
Pembroke v. Peninsular Terminal Co.
108 Fla. 46. 146 So. 249 (1933) .....
•
Page
MI •
CITATIONS OF AUTHORITIES (CAnued)
Case
Page
Poladran v. Johnson
85 So.2d 140 (Fla. 1956) ....._ ED_ 15,. 16
Price v. Stratton
45 Fla. 535. 33 So. 644 (19013). 28
Reed v. Fain
145 So.2d 858 (Fla. 1962), M.
Sawyer v. itlodra!!
286 So.2d 610 (4th Fla. DCA t9i73)), cut_ denied,:
297 So.2d 562 (Fla. 1974) _ . 2C,.. 25°
Shelter v. C'itt' of Pensacola
112 Fla. 584, 151 So. 53 (1933). ... ..... 18'
Smith Bros. v. Williams
100 Fla. 667, 131 So. 335 (1930) .... t6, 17
. 22
State ex rel. Ellis v. Gerhing
56 FIa. 603, 47 So. 353 (1908) ...
State v. Mitchel!
188 So.2d 684 (4th Fla. DCA. 11966)t _ _ _ _ ., .... 10
Stone v. Town of ;Mexico Beach
348 So.2d 40. 43 (1st Fla. DCA. 19,77):. < 10s, 17
Thiesen v. Gulf F .t , l R r. Co.
75 Fta. 28. 78 So. 491 (1918) ... _ . _ .. _ .. ... 16
, 1 , 11, Mill,111111
A
1 '''1 ' 11'
II
1,;I'� 11111'
■
1111
i
CITAi IONS OF AUTHORITIES (Continued)
.Case
Trustees of Tufts College r. Triple R. Ranch. Inc.
275 So.2d 521 (Fla. 1973)
ll'ernle v. Bellcntead Der. Corp.
308 So.2d 97 (Fla. 1975)
Wright v. Blocker
144 Fla. 428, 198 So. 88 (1940) .
Federal
City of El Paso r. Sinttnons
379 U.S. 497. 85 S.Ct. 577, 13 L.Ed.2d 446
(1965), rehearing denied, 380 U.S. 926 (1965) .
Page.
Curtis v. Loether
415 U.S. 189, 94 S.Ct. 1005, 39 L.Ed.2d 260
(1974)
Er:no:nik v. City of Jacksonville
422 U.S. 205, 95 S.Ct. 2268,
45 L.Ed.2d 125 (1975) ..............
Home Building & Loan Ass'n v. Blaisdell
290 U.S. 398, 54 S.Ct. 231,
78 L.Ed. 413 (1934)
Mullane v. Central Hanover Bank & Trust
339 U.S. 306, 70 S.Ct. 652,
94 L.Ed. 865 (1950)
iv
1 I'' I
•
I■1■1111
11
IIIIIIII■IIIII
IIIIIIiiiiuiIi■uI
CITATIONS OF AUTHORITIES
Case
Shaw v. ;North Pe>utsylrania Ry. Co.
101 U.S. 557. 25 L.Ed. 892 (187% .....-
L1 age
1!0f
United States v. State of California
381 U.S. 139, 85 S.Ct. 1401. 85 L.Edi_ 140111'
(1965), rehearing denied. 382 U.S. 8891(1965)1.,.. 1141
U.S. Civil Service Commission v.
;National Ass'n of Letter Carriers
413 U.S. 548. 93 S.Ct. 2880,
37 L.Ed.2d 796 (1973)............
: 118
United States Trust Co. of 4Vew• York v e:*':-:11efsey"
U.S. , 97 S.Ct.
l Ed.2d (1977) ......... _ ... ...... C49+
Twolithlet' r. City of Long Beach
333 F.2d 685 (9th Cir. 1964), cert. denied, 85
S.Ct. 195 (1965)
McKnight ''. Broedell
212 F.Supp. 45 (E.D. Mich. 196&2)
C4
2T, 24
United States v. 2.899.17 Acres of Land. Etc_
269 F.Supp. 903 (M.D. Fla. 1967) :._. 21.24
Other Jurisdictions
State v. Zimring
566 P.2d 725 (Hawaii I977'
ill!11!IIIIU,UIVl�I7II�,�.!';;1�1,,.�,��1
1111 Pll1111llu,l
11111111111
i
i
('17.'tIONS OF .\U 1'IIORITIFS (Continued)
I'agc
Case
1111101,1
Statutes
Florida Efficient
L. A Handbook for More
Simes.
.:... .:4-3'1 cin 1961)1
..... ... ... .
s Chapter-7=12;;=� Conveyancing (
Florida Statute
Case
CITATIONS OF AUTHORITIES (Conti! d)
(~'age
21, 23, T4�.
Fla. Stat. §712.04 � :,: r:,:�:; i:- • ' -'
• 26, 30 -
Federal
Title 43 United States Code § § 1301 et `s
Title 43 United States Code § 1311
Textual Authorities
American Law of Property §17.17
Barnett. Marketable Title Acts — Panacea or
Pandemonium, 53 Cornell L.Rcv. 45 (1967)
Black's Law Dictionary (4th ed. 1951)
1 Boyer, Florida Real Estate Transactions (1976)
92 C.J.S. 1024 (1955)
Dickerson, The Interpretation and Application
of Statutes (1975)
Johnson, Purpose and Scope of Recording
Statutes, 47 lowa L.Rev. 231 (1962)
vi
'I I
Sands, Sutherland Statutory Construction
(4th ed. 1973)
01,,r767.111;' 1191"I J
lf�
1111.1111
111
iuiiuiiui
TABLE OF CONTENTS
Page
STATEMENT OF THE CAST:
STATEMENT OF THE FACTS
QUESTION PRESENTED .
it
ARGUMENT
THE CITY'S OWNERSHiP OF THE SUB-
JECT LAND IS NOT EXTiNGUISH BY'
1 HI: MARKETABLE RECORD TITLES'.
ACT.
1. Respondent's "Title.' Derives From a R'ild
Deed Which Is Therefore Void.
2. Chapter 712 Does Not A ppl y To Wild Deeds. 6_ 1
(a) A Void Instrument Cannot Be
Validated By The Passage of Time.
(b) The Concerns Expressed By Mr. Harris
Do Not Support The Applicability of Chapter) I-E 3
712.
(c) The inapplicability of The Act To Wild
Deeds Is Supported By Textual Authorities. ... 13,
(d) Even If The Act Applied to Void instru-
ments, The City's Ownership Would Not Be Ex 3-1
tinguished.
viii
,I1
II
TABLE OF CONTENTS (Continued)'
3. . is Interpreted Below. The .act F. Urrcotr,- r 201
stitntionctl.
(a) The Act As Interpreted Below Con-
stitutes A Deprivation of Property Without Due L°-t=-iC6
Process
(h) Retroactive Application Of The Act l'6-
Violates Due Process
17
(c) The Act Should Be Construed To Avoid 17_18
Unconstitutionality.
(d) Chapter 712 As interpreted Below
Results In An Unconstitutional Taking of 1$
Property Without Just Compensation.
(e) The Act As Interpreted Below Is An
Unconstitutional impairment of Contract. 1.4 20
4. Respondents Cite Nothing To Support The
Holdings of the Courts Below That Chapter 712
Extinguishes The C'itr'.s Ownership. As .`I'n
Agency of The State, of This Sovereignty Lund. 20-26
5. The Trial Court Improperly Made a Factual 1
7-1
9
Determinutiun of Estoppel. `
�
Ri a,ul ,�i,j !II!
i
11
111
1111111111111111111
11
111
11111111
1111111111
111111
111
11111111111111
CONCLUSION
OF ('ONTEN"I'S (Continued)
CERTIFICATE OF SERVICE .,
Page
in the
%yreme Court of 3fturiba
CASE NO. 51,775
CITY OF MIAML
a Florida municipal corporation„
Petitioner.
Vs.
ST. JOE PAPER COMPANY,.
a Florida corporation:
SOUTHEAST PROPERTIES, INC.,
a Florida corporation;
EIUGH E. MATHESON, JR., individually; and
SALLY S. DOMMERICEI, formerly
Sally S. Matheson, individually,
Respondents.
PETITIONER'S REPLY BRIEF
STATEMENT OF THE CASE'
•
The decision of the court below has now been reported.
City of Miami v. St. Joe Paper Co.. 347 So.2d 622 (3d Fla.
DCA 1977).
'The abbreviations used in Petitioner's Main Brief will be continued
herein.
f9
STATEMENT OF THE FACTS
Petitioner agrees with Respondents Southeast Proper-
ties. Inc.. and Sall}' S. Dommerich. that the facts with
respect to all Respondents are the same as those with
respect to St. Joe. cwccpt that the Respondents other than
St..loc claim by deeds from St. Joe subsequent to 1944. and
that the "yacht basin" is claimed only by St. Joe. See
Amended Complaint. ' ' 14. 15. App. 78-79.
u 1I1
lb
IIIIIU■U
QUESTION PRESENTED ' ►
WHETHER IT \VAS ERROR TO DIVEST
THE CITY OF ITS SBIDRANT RETROS OF
SOVEREIGNTY
EC-
TIVI: VALIDATION OF a WILD DEED.
A
1„,„,01, ,,,,,,.,,,,,,4,,,„,„„ h ININ,1,,,
rl
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11IIIIIIIIIII III
i
1111
1
•
i
ARGUMENT
NT
THE C'ITY'S OWNERSHIP 01- THE SUB-
JECT LAND 1S NOT 1.XTINGUiSHED BY
THE MARKETABLE RECORD TiTLES
ACT.
1. Respondent's "Title" Derives From a Wild
Deed Which i.s Therefore Void.
2. Chapter 712 Does Not Apply To 11'ild Deeds.
(a) .\ Void instrument Cannot Be :-
Validated By The Passage of Time.
(b) The Concerns Expressed by Mr. Harris
Do Not Support The Applicability of Chapter
712.
(c) The inapplicability Of The Act To Wild
Deeds is Supported 13 Textual Authorities.
(d) Even if The Act Applied to Void instru-
ments, The City's Ownership Would Not Be Ex-
tinguished.
3. ;1s Interpreted Below. The ,•let Is Uncon-
stitutional.
(a) The Act As interpreted Below Con-.
stitutes A Deprivation of Property Without Due
Process.
(b) Retroactive Application Of The Act
Violates Due Process.
4
iii uu■iiiii■■i11■1 1
'I I
I II II II,
(c) The Act Should Be Construed To Sioid
Unconstitutionality.
(d) Chapter 712 As Interpreted Below
Results In An Unconstitutional Taking of
Property Without .lust Compensation.
(e) The Act As Interpreted Below is An
Unconstitutional Impairment of Contract.
4. Respondents Cite Nothing to Support The
Holdings of the Courts Below That Chapter 71:
Extinguishc'.c The ('ity'.s Ownership, .'ls :In
Agency of The State, o/ This Sovereignty Land.
5. The Trial Court Improperly Made a Factual
1)eter►nination of Estoppel.
Marealtil
I
IIUI�I I!IIII I
iI,'1!lpIII
ICI111 �!�
f lil1111111 , 1
hI II
ARGUMENT
THE CITY'S OWNERSHIP OF TIIE SUB-
JECT LAND iS NOT EXTINGUISHED BY -
THE MARKETABLE RECORD TiTLES
ACT.
1. Respondents' '.Title.. Derives Froin .-1 INN
Deed Which Is Therefore I'oid
Respondents base their claim to the land in question on
a 1944 deed from EEC to St. Joe. FEC did not have record
title to the land. When it purported to convey that land in
1944. the deed was wild and therefore void.
St. Joe states that the 1944 deed is not wild because
EEC held record title to the initial 14 acres "together with
all and singular the riparian rights and submerged lands ap-
pertaining thereto."
If St. Joe's contention were correct. FEC would have.
held record title by a wild deed to the Atlantic Ocean bot-
tom. In fact and in law, the boilerplate language
notwithstanding. EEC held record title to nothing more
than the initial 14 acres. Land does not pass appurtenant to -
land. Because Hagler owned only to the high water mark,
there were no "submerged lands appertaining thereto." The
boilerplate phrase is meaningless.
2. Chapter 712 Does Not Apply To Wild Deeds
(a) A Void Instrument Cannot Be Validated By
The Passage of Time
•ii■ii■iui ■.1Il
St. Joe in its brief distorts the City's argient, the law
of property, and this Court's holdings in iTT Rayonier.
Inc. v. Wadsworth. 346 So.2d 1004 (Fla. 1977), and
;tlarshall v. Hollywood. Inc.. 236 So.2d 114 (Fla. 1970), in
trying to defend the alchemy performed by the courts below
in breathing life into a wild deed.
The courts below have held that St. Joe's wild deed has
ripened into good title by the mere passage of time. St. Joe
argues that this result is supported by atarshall and iTT
R'ayonier. `either case is on point.
;A wild deed is one purporting to convey land to which
the grantor did not have title. Because the grantor did not
have tide. the deed does not appear in the "chain of title" —
i.e.. the true owner of the land cannot discover the deed: by
searching the grantor/grantee indices. Thus the deed does
not convey notice to the true owner. and is void.=
St. Joe and Nir. Harris' argue that the basis for
divesting a feeholder is the feehoider's "neglect" in failing
to protect his ownership from competing claims. But a fee -
holder cannot he negligent in failing to protect his
ownership from a claim of which he had no notice. Such
"neglect" cannot form the basis for title in a void
..competing claim." See. e.g.. City of Miami v. Benson, 63
So.2d 916, 923 (Fla. 1953):
'Reed v. Fain, 145 So.2d 858 (Fla. 1962); Poladian v. Johnson, 85 So.2d
140 (Ha. 1956); Wright v. Blocker. 144 Fla. 428. 198 So. 88 (1940); Braddy &
Ilale Fishery Co. v. Thomas. 93 Fla. 326. 112-So. 55 (1927): American Law of
Property § 17.17.
'See n. i 1, infra.
7
11111101,11,111111111111,1.111111
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hill
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"Life - nnot be breathed into a void contract
[merelylhecause the completion of the void con-
tract would render a useful purpose in ac-
complishing desired ends or because it is ex-
pedient.'
`either Marshall nor ITT Raronier involved a wild•
deed. Marshall held that the Act could extinguish
ownership in favor of a root of title arising out of a forged -
deed — in such a case the forgery appears. albeit
•
fraudulently, within the same record chain of title by which
the true owner claims. ITT Ravonier held that the Act
could extinguish the remaindermen's interest in favor of a
root of title whereby the life tenant purported to convey fee
simple to herself and another as tenants in common. Again.
the root of title appears in the same record chain. in both
cases. the plaintiffs had notice of the competing claims, by
virtue of the fact that the claims appeared in their respective
chains of title — i.e.. they were discoverable by a search of
the grantor/grantee indices. No Florida case holds that
Chapter 712 can extinguish property ownership in favor of
a stranger to the title.
The City in its main brief argued that the Act should
not apply to wild deeds, that the Act could not con-
stitutionally apply to wild deeds. and that the Act by its
terms did not apply to wild deeds. Although ITT Rayonier
does use language which appears to be contrary to the
statutory construction arguments advanced by the City in
'See also Smith Bros. v. Williams. 100 Fla. 667. 131 So. 335. 337 (1930)
(subsequent legislation cannot validate an act void ab initio: legislation cannot
"breathe life into a corpse.").
8
I_I MIN
its main brief.` the controversy there was of su Ott nature as
not to he preclusive of a clarification of that case's actual
holding. This Court should now hold that a deed which is
"void" in the strict sense, i.e., outside the record chain of
title, does not "affect title" and cannot he validated by
Chapter 712. A void instrument is "nugatory and ineffec-
tual so that nothing can cure it.' Black's Law Dictionary.
p. 1745 (4th ed. 195 l ). A void deed is not a recorded instru-
ment affecting title.'
Recording statutes themselves drastically depart from
the common law rule that even a bona fide purchaser takes
no better title than his transferor had.' A purported con-
veyance of more than the transferor had may in certain cir-
cumstances create good title. if the instrument is recorded
within the chain of title; the true owner has notice of this
competing claim, and he may be precluded from successful
challenge by his own inaction in the face of notice. Thus the
improper conveyance is merely "voidable" and may be
cured.
The same is not true of a deed outside the chain of title.
which imports no notice and is therefore not merely
voidable but void.
'The court in ITT Rcn•unier quoted with approval
he �13 urth th FlaD.istrict
DC
Courts opinion in Marshall v. Hollywood. Inc..
224. A
1969):
"'In this broad sense. even a void instrument of record' affects' land
titles by casting a cloud or a doubt thereon.'
224 So.2d at 1010.
^See n. 2, supra.
'See generally. Johnson, Purpose and Scope of Recording Statutes, 47
Iowa L.Rev. 231 (1962).
i
1111
92 C.,r:` 1024-1025 (1955) states the distinction as fol-
lows:
"[T]he word `void' implies an act utterly of no ef-
fect, and, in its most unlimited sense, implies an
act of no effect at all, and a nullity ab initio.. . .
On the other hand. a `voidable' act may be cured
by passivity, ratification. or acquiescence.'
This Court has held that a voidable deed (a forged deed
in Marshall: a deed purporting to enlarge the grantor's es-
tate from a life estate to a fee simple in ITT Ravonlier) may
be cured by Chapter 712. The plaintiffs in those cases had
legal notice of the adverse claims recorded within their
respective chains of title. A wild deed, on the other hand,
"hung out in the air like Mahomet's coffin,' cannot be
validated by Chapter 712. Such a retroactive validation
would be inconsistent with the basic principles of property
law" and with the constitutional protections of vested
property rights.''
"Poladian v. Johnson. 85 So.2d 140. 141 (Fla. 1956).
"See Stone v. Town of Mexico Beach, 348 So.2d 40 (4th Fla. DCA 1977):
Ellis v. Brown. 77 So.2d 845. 847 (Fla. 1955) ("statutes are to he construed in
reference to the principles of the common law: fo, it is not to be presumed that
the legislature intended to make any innovation upon the common law further
than the case absolutely required."). Gonzales v. City of Belle Glade. 287 So.2d
669. 670 (Fla. 1973): State v. Nlitchell. 188 So.2d 684, 688 n.11 (4th Fla. DCA
1966); Johnson v. State, 178 So.2d 724, 728 (2d Fla. DCA 1965): see also Shaw
v. North Pennsylvania R. Co.. 101 U.S. 557. 565. 25 L.Ed. 892 (1879).
"See n. 17. infra.
10
111111111111111111
(h) The Concerns Expressed By Mr. Hat. Do
Not Support The Applicability Of Chapter
712"
Mr. Harris's expressions concerning the history of
Chapter 712. though somewhat tinged with hyperbole,'
may he essentially correct, hut are totally irrelevant to this
case. The City does not quarrel with the fact that the Act is
an attempt to deal with a legitimate prohlem. Bura more
accurate description of the problem would he "pesky,'
rather than "fundamental." The problem of technical er-
rors and "stale claims" can hardly serve as a basis for dis-
regarding constitutional protections of property rights,
which are. by definition, fundamental.
'The brief is self-styled a "Brief of Amici Curiae for and' on behalf of the
Florida Bar." The "Florida Bar" in this case is the executive council of one sec-
tion. energized by the written suggestions of St. Joe's counsel that St. Joe's
position should be supported. The brief is nor filed "for and on behalf of the
Florida Bar."
It is subject to some question that the pre-I963 life of Florida citizens or
even "title lawyers" 'whatever they may bet was really the "intolerable burden"
of one conveyancing after another "fraught with danger." as Mr. Harris sug-
gests.
1111
II
11
i
1
Mr. I...iris. s "history" of Chapter 712 accurately
omits any legislative intent to resolve conflicts between two
separate chains of title to the same property, one traceable
to the sovereign and one traceable only to a wild deed."
The Act's purpose is to remove clouds on title from
fees simple. The purpose is not to extinguish fees simple. A
fee simple does not cloud a non-existent title."
�n authority heavily relied upon both by Mr. Harris and by St. Joe ac-
curately expresses the real purpose of curative legislation.
"It is inevitable that minor errors appear in recorded instruments.
for human nature is not infallible. Thus there may he variations in
the names of parties, failure to indicate the marital status of gran-
tors. failure to comply with the precise requirements of the statute
concerning the form of acknowledgements, and many other devia-
tions from a standard of absolute perfection.. . . There are also
many facts necessary to a marketable title which are essentially ex-
trinsic. but which are commonly only recited on the record. Thus if the
recorded deed recites that the grantor is a single man. or that his wife
is W. who joins in the conveyance. these recitals are not conclusive.
Vet the title examiner. as a practical matter must rely on them, and
•
will rarely investigate the actual facts. The great need is for some
legislative device to reduce the namb.r of extrinsic facts which must
be considered by the title examiner.. . .Asa practical matter. the
only property interests sshich are generally marketable are fees sim-
ple absolute. leases for years. and fees simple subject to such leases.
An future interest which is to take effect in possession at an uncer-
taro time. whether it be technically vested or not. is not readily
marketable. Nor is the present interest subject to such future in-
terests marketable.
L. Simes. a tlandhook for More Efficient Conveyancing. 33-36 (1961). See also
Barnett. Marketable Title Acts — Panacea or Pandemonium. 53 Cornell
L.Rev. 45 (1967).
"Before Chapter 712 was conceived, principles of law were developed to
prevent a lax or negligent feeholder from inequitably restricting the free
alienability of realty — e.g., adverse possession and title by tax deeds.
Chapter 712 was not enacted to extend such doctrines. The Act expressly
exempts owners in possession and those on the tax rolls.
If upheld. the decisions below would mean that a record feeholder not in
possession. but against whom a successful claim of adverse possession cannot
be made, is nevertheless subject to divestiture on the basis of a wild deed.
12
III
A statute enacted in the interests of ..1.11 security
should not be construed to divest a feeholder in favor of a
wild deed.
(c) The Inapplicability Of The Act To Wild
Deeds Is Supported By Textual Authority
Making the accusation of misuse of 1 Boyer, Florida
Real Estate Transactions. r 14.14-11 (1976),
"[A]ny interest reflected in the root or in the
recorded chain in that time, will have to be
checked out hack to its source."
St. Joe asserts this "clearly" only refers to those interests
enumerated in y7I2.03. St. Joe offers no support for this.
position. In fact, the December, 1976 supplement to this
text states, citing Marshall v. Hollywood. that "a root of
title may arise out ()la forged or a wild deed, but apparently
a forged deed itself cannot serve as a root of title" (At 78,
emphasis supplied). The conclusion is clear: a title searcher
finding a root of title at least 30 years old, wanting to assure
the marketability of any interests, must determine that the
grantor of that interest himself had title. The root must he
"checked out back to its source.'
(d) Even If The Act Applied To Void Instru-
ments, The City's Ownership Would Not Be
Extinguished
The City has contended throughout this litigation that
a void deed has no legal effect, even under Chapter 712. If
this position were rejected, however, the City's ownership
has been reaffirmed, as a matter of law, by a "title transac-
tion" (as Respondents would have the Court define them)
13
I
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— for in 19.1 the United States quit -claimed its interests in
this property to the City of Miami.'`
3. .•is Interpreted Below. Thc' Act Is Uneon-
•
Stitutiuncll
(a) The Act As Interpreted Below Constitutes A
•
Deprivation Of Property Without Duc
•
Process
Respondents assert that the constitutionality of: -
Chapter 712 must be decided on the basis of a "balancing of -
interests." St. Joe portrays those interests to he balanced as
(a► the States interest in title security, and (h) the burden of
re -recordation. in fact, the interests "to he weighed"
against title security would not he the burden of re -
recordation, but would he the resulting divestiture of vested
property interests.
-13 Hinted States Code j131I, 67 Stat. 30 (stay 22. 1953):
'la) It is determined and declared to he in the public interest that
tl► title to and ownership of the lands beneath navigable waters
%%Ain the boundaries of the respective states. and the natural
resources within such (ands and waters. and (2) the right and power
to manage. administer, lease. develop, and use the said lands and
natural resources all in accordance with applicable state law he. and
they are, subject to the provisions hereof, recognt ed, confirmed. es-
ruhlohed, tested in and assigned to the respective states or the
persons who were on June 5. 1950. entitled thereto under the law of
the respectne states in which the land is located, and the respective
grantees . . or successors in interest theren/.'• (emphasis supplied(
See United States %. State of California, 381 U.S. 139, 85 S. Ct. 14(11. 85 L.Fd.:'
1401 (1965). holding that the Submerged Lands Act. 43 United States Code
1301. et seq., is in effect a quit -claim deed from the United States of sub-
merged coastal lands.
Twombley %.City of Long Beach. 333 F.2d 685 (9th Cir. 1964), holds thata
City to which the State conveyed submerged lands subject to a public trust did
not acquire such lands free of the trust.
14
St. Joe argues that this possibility of c,stiture is
rendered irrelevant by the notion that all persons having
record title to real estate in 1963 had "constructive notice"
that they had to file a notice of their ownership or be sub-
jected to divestiture within two years.
This legal fiction of constructive notice has no
talismanic quality. Due process requires notice "such as one
desirous of actually informing. . .might reasonably adopt
to accomplish it." Mullane v. Central !Hanover Bank
Trust Co.. 339 U.S. 306, 315, 70 S.Ct. 652. 94 L.Ed. 865
(1950).
Due process is not satisfied by presuming that the
enactment of Chapter 712 gave notice to property owners
that they must re-record their ownership or have it divested
in favor of a wild deed, of which — as a matter of Florida
law — they did not have notice.
Properly applying the Act only to deeds other than
wild deeds, holders of property interests could be deemed to
have notice of conflicting claims duly recorded. Here,
however. the courts below would extinguish the City's es-
tate before it had notice of the conflicting claim:
"The recordation of void . . . deeds is legally in-
sufficient to convey notice and affords no protec-
tion to the claimant thereunder."
Wright v. Blocker, 144 Fla. 428, 198 So. 88, 90 (1940).
This Court holds that recording of a wild deed is not
notice of a claim to property., a wild deed is one executed by
a stranger to the record ia�rly. Johnson, gSout tn So.hd 140,e air 1ike
141
Mahomet's coffin.-
(Fla. 1956).
is
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• 11E0111
The '4 conveyance was a wild deed in 1944, and can-
not be made valid by subsequent legislation. An act cannot
"breathe life into a corpse." Smith Bros. v. Williams. 100
Fla. 667. 131 So. 335. 337 (1930).
St. Joe argues that the City in fact had notice of St.
Joe's claim." This argument is both incorrect factually and
irrelevant. The question is not whether the City in fact had
notice. The question is whether the ;Net as construed below
provides the notice required by due process.
(h) Retroactive Application Of The Act
Violates Due Process
St. Joe and Mr. Harris respond to the City's argument
that the retroactive application of the Act renders it uncon-
stitutional by citing cases upholding retroactive application
of statutes of limitation. The distinction between Chapter
712 and statutes of limitation. which St. Joe and Mr. Harris
emphasize in the introductory portions of their briefs. is
crucial. Retrospective legislation is invalid
" . . . when a new obligation or duty is imposed
or an additional disability is established in con-
nection with previous transactions."
'Hut nothing has been alleged which would charge the City with such'
notice. The recordation of a wild deed did not charge the City. The filing and -
acceptance of a plat did not charge the City. The payment of taxes did not,
charge the City. See Poladian v. Johnson. h5 So.2d 140 (Fla. 1956). w'ernle v.
Hellcmead Dev. Corp., 308 So.2d 97 (Fla. 1975): Thiescn v. Gulf h&A Ry. Co..
75 Fla. 28, 7ti So. 491 (1917).
In this regard, see also the Amended Complaint. subparagraph f of the
Prayer for Relief. App. 88.
Furthermore, the event relied upon by St. Joe as importing notice to the
City, i.e., the acceptance of a plat, did not occur until 1949, less than 30 years
before the City's Complaint. See Amended Complaint *16, App. 79.
16
Stone v. Town o/. rttexieo Beach. 348 So.2d 40;(I st Fla.
DCA 1977), citing McCord v. Smith. 43 So.2d 704, 709
(Fla. 19501 (emphasis supplied).' Retroactive application
of statutes of limitation do not impose a new hurden—all
claimants were already required to file suit to enforce their
claims. However, prior to the enactment of Chapter 712,
landowners were not required to re-record their interest to
preserve their ownership. Now, according to the Third
District's interpretation of Chapter 712, they are so re-
quired. If landowners are unaware of this new retroactive
requirement, they are subject to divestiture. This result can-
not he constitutional.''
(c) The Act Should Be Construed To Avoid Un-
constitutionality
Mr. Harris argues that the City is not a "person'
within the meaning of the Fourteenth Amendment. and
thus cannot assert the unconstitutionality of Chapter 712 as
applied. The argument is irrelevant to this case.
'McCord is followed in Trustees of Tufts College v. Triple R. Ranch, Inc..
275 So.2d 521, 525 (Fla. 1973) ("a statute should not he given retrospective ef-
fect when it jeopardties the validity of the statute.") See also Creary v. Estate of
Cream. 33h So.2d 26 (1st Fla. DCA 1976): In re Estate of Jeffcott, 186 So.2d
80 (2d Fla. DCA 1966). Cf. Smith Brothers v. Williams, 100 Fla. 667, 131 So.
335, 337 (193() (void legislation cannot he validated by subsequent legislation:
legislation cannot, by subsequent act. "breathe life into a corpse.").
"In Biltmore Village v. Royal. 71 So.2d 727 (Fla. 1954). a statute cancel-
ling all reverter provisions in plats or deeds which had been in effect more than
21 years was held unconstitutional as an impairment of contract. Mr. Harris
seeks to distinguish this by saying that commencing a lawsuit is an intolerable
hurden. while filing a notice under Chapter 712 is not. This distinction finds no
support in Biltnwre. The case is more properly explainable by reference to Mc-
Cord. Retrospective legislation imposing a new obligation or duty to preserve a
vested right is unconstitutional.
I!7
Iq'.!III�IIIIII11AlIi!
i
"i'his i.. A a case where the City has brought suit to en-
join state action. Unlike She/by v. ('itt• of Pensacola. 112
Fla. 584. 151 So. 53 (1933). the City is not challenging a
statute dealing specifically with the City. The City is saying
simpIN that Chapter 712 cannot he construed to mean what
the trial court and the Third District held it to mean —if the
Act did mean that, it would he unconstitutional. It is
elementary that statutes should be construed to ,Void un-
constitutionality.'" Surely Respondents do not suggest a
double -standard of the Act: it means one thing as to cities
and another as to private parties.
(d) Chapter 712 As Interpreted Below Results
In :\n Unconstitutional Taking of Property
Without .lust Compensation
St. Joe and Mr. Harris fail to respond in any way to
the City's argument that the decisions below are an uncon•
-
stitutional "taking" of property. This failure is not inadver-
tent. It is a necessary concession of the point by silence.
•1 mhart Corporation Brantley, 257 So.2d 273, 275 (3d Fla. DCA 1972)
('"courts gill eserct.e judicial restraint to avoid declaring a statute uncon-
stitutional, and gill give it a construction, if reasonable, tthich would preserve
the statute...): 2.\ Sand., Sutherland Statutory Construction §45.1 I (4th F.d.
197 3)1-the fact that one among alternative constructions could involve serious
constitutional difficulties is reason to reject that interpretation in favor of
another."). see also I1rrnornik v. City of Jacksonville. 422 U.S. 205. 95 S.Ct.
2268, 45 1..I:d.2d 12_5 (1975): Curtis v. Loethor, 415 U.S. I fi9.94 S.Ct. 1005, 39
L1:d.2d 2o0 (1974). 1..S. Civil Service Commission v. National ,\s n of 1 etter
Carriers. 413 1--S. 5-0s, 93 S.Ct. 2850, 37 1..1'd.2d 796 (1973).
.1 he result urged by Mr. I Iarris is that even if Chapter 712 as interpreted
helo s is unconstitutional as applied to "persons." it is not unconstitutional as
applied to the City — leaving a general act applicable only to cities. Such a
position is untenable.
The fact that Mr. Ilarris resorts to this argument betrays the impossibility
of reconciling the interpretation of Chapter 712 rendered by the courts below
with cnrstitutional protections of vested property rights.
18
1
1111
111111I11.II11IIIIII IIIu■1 .uII
(e) The Act As Interpreted Below Is An Uri;.t-
stitutional impairment Of Contract
St. Joe and Nlr. Harris cite C'itr n/ El Paso v. Sint-
mon.t.. 379 11.S. 497, 85 S.Ct. 577. 13 L.Ed?d 446 (1965)
and Home Building & Loan ."l.ss n v. Blaisdell. 290 U.S>.
398. 54 S.Ct. 231, 78 L.Ed. 413 (1934). as supporting their
argument that Chapter 712 is a reasonable exercise of the
police power and thus not violative of the contracts clauses
of the federal and Horida Constitutions.
Both of these cases. and the Contracts Clause in
general. were discussed extensively by the United States
Supreme Court in United States Trust Co. of Nov York v.
tie►t•Jersey. 97 S.Ct. 1505 (1977). The plaintiffs in that case
challenged a New Jersey statute repealing a statutory cove-
nant made in 1962 that had limited the ability of the New
York and New Jersey Port Authority to subsidize rail pas-
senger transportation from revenues and reserves. The
court held that this repeal was prohibited by the Contracts
Clause. In discussing Simmons and Blaisdell, the court
stated:
"Both of these cases eschewed a rigid application
of the Contracts Clause to invalidate state legisla-
tion. Yet neither indicated that the Contracts
Clause was without meaning in modern con-
stitutional jurisprudence. or that its limitation on
state power was illusory. Whether or not the
protection u/ contract rights comports with cur-
rent views ul wise public policy, the Contracts
Clause remains a part of our written con-
stitution."
97 S.Ct. at 1515 (emphasis supplied).
t9
pll
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111'11
111111
i
1I!II 1
i
11111111
1111
The urt responded to the argument that the repeal
was a valid exercise of the police power in the interest of
mass transportation, energy conservation, and environmen-
tal protection:
"Vet the Contracts Clause limits otherwise
legitimate exercises of state legislative authority, •
and the existence of an important interest is not
always sufficient to overcome that limitation.. .
Moreover. the scope of the state's reserved power -
depends on the nature of the contractual
relationship with which the challenged law con-
flicts.
97 S.Ct. at 1517.
The Court concluded that the statute could not stand if
there were available less drastic alternatives:
". . . it cannot he said that total repeal of the
covenant was essential: a less drastic modification
would have permitted the contemplated plan
without entirely removing the covenant's.
limitations. . .
97 S.Ct. at 1522.
The interpretation of Chapter 712 rendered by the
courts below is clearly not necessary to achieve title.
security.
4. Respondents Cite Nothing To Support The
Holdings Of. The Courts Below That Chapter
712 Extinguishes The City's Ownership, As
20
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II
IIIIII
III
i
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1111
IIII■IIIIuI 1,M11IuI■■ I.
„An Agency O:/ The State, O'r'hi:s
Sovereignty Land
Chapter 712 expressly exempts from its provisions:
"any right, title or interest of the United States,
Florida or any of its officers, hoards. commis-
sions, or other agencies reserved in the patent or
deed by which the United States. Florida or any
of its agencies parted with title...
Fla. Stat. §7I2.04.
It has been held that the Act can in some instances ex
tinguish governmental ownership of land. hut only that
which has been conveyed away from the State without -
reservation. Odour v. fcltona Corporation. 341 So.2d 977
(Fla. 1977):.Satt_t•e'r v. atodrall. 286 So.2d 610 (4th Fla.
UCA 1973). It has not been and cannot be held that the Act
extinguishes governmental ownership of land which has
never left the State or its agencies in the first instance.
The State has parted ss ith title only once — conveying
it to its agent the City of Miami "for municipal purposes
only." The City of Miami has never parted with title. The
City's title cannot he extinguished by the Act.
The land in question is sovereignty land. The State of
Florida accepted this land from the United States, upon ad-
mission to the Union. subject to a trust for the benefit of the
people of the State.
The State cannot alienate this land in a manner incon-
sistent with this public trust. A general act, such as Chapter
712, cannot be construed to divest sovereignty lands in
favor of a wild deed.
21
II
pI�
II I
i
i
m
the prior purported State conveyance were for some reason
voidable —St. Joe is charged with notice of the navigability
of 13isca , ne Bay.
In this case there is not even such a purported con—
veyance out of the State. The State and its agencies have
never parted with title. The City's ownership is therefore
protected From extinguishment by 1=1a. Stat. ti712.O4.'i
St..loe and Nir. Harris argue that the express language
in the legislative grant limiting use by the City to
"municipal purposes only" does not constitute a reserva-
tion by the State within the exception in § 712.04. 1'his argu-
ment is irrelevant as well as incorrect." Mr. Harris urges
1t..luc also misreads Justice Sundberg's dissenting opinion that the Act
cannot extinguish the Slate's interest in sovercifrnty lands. St Joe refers to
Justice Sundherg's point that the effect of apphmg Chapter 712 to the facts in
%vas to alienate submerged land held by the Trustees of the Internal
Impronenicnt fund absent the requisite s:tteguard. of statutory notice and hear-
ing. St Joe then offers the following distinction:
"In the case at bar. by virtue of the fact that the conteyance from the
Mate to the C.ity of Miami was caused by the legislature's enacting a
special statute. such requisite safeguards of public notice and hearing
obviously were met." (St.Joe's brief. page 8.)
The City would respectfully submit that St. Joe has missed the point. No one.
certainly not the City of Miami, is challenging the conveyance of sovereignty
lands from the State to the City of Justice Sundherg's point is that it is
constitutionally impermissible for the State to convey submerged lands away
from the State without the requisite safeguards. It therefore cannot he held that
state legislation li.c.. Chapter 712) by implication extinguishes the ownership of
the State's agent in this sovereignty land. The piracy of sovereignty land
through recurdatiun of a wild deed is wholly inconsistent with the public in-
terest.
:: the State of Florida is not directly in ,his litigation protecting its
property interests in this land. The Court is not called upon to determine what
rights and remedies the State of Florida would have against St. Joe if the deci-
sion of the courts below is upheld. However, acceptance of the St. Joe and Har-
ris position would result in the alienation of an inalienable trust. See Flayes v.
Bowman. 91 So.2d 795 (Fla. 1957); Pembroke v. Peninsular Terminal Co.. 108
Fla. 46, 146 So. 249 (1933); United States v. 2,899.17 Acres of Land. Etc..269
F.Supp. 903 (MLD. Fla. 1967). See also, McNight v. Broedcll, 212 F.Supp. 45
(E.1). Much. 1962).
24
111111111111111111N
11111111111111
111111111111111111111
11111
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1111
Savvier t'. illodrnll, 286 So.2d 610 (4th Fla. DC.A 1973),
cert. denied, 11)7 So.2d 562 (Fla. 197.4) as support. The
court in that case held that there is no implied reset vation
when the State conveys sovereignty land. But Sawyer did
nut involve a conveyance by the State with an express use
restriction.
The importance of the use restriction in the present
case is that it establishes that the City in its ownership- of
this land is acting as an agency of the State. St. ,toe at-
tempts to distinguish the agency cases cited in the CityF's
main brief h., arguing that they
. . . are nut in point because they relate to
governmental functions that have been expressly
delegated to cities for implementation and do not
pertain to proprietary or land title matters where -
cities compete with their citizens and taxpayers on
equal basis under the law.— (St.Joe's brief, page
13.)
Mr. Harris adopts the same argument.
The legislative grant "for municipal purposes only"
preserves the public trust in which the State held the lands,
and reflects the legislative realization of the limitations on
its power to alienate these lands. The City in its ownership
of this land is performing a governmental function express-
ly delegated to it by the sovereign.'
Sec Alhury v. Central and Southern Florida Flood Control District, 99
So.2d 248. 252 (3d Fla. DCA 1957):
—Government exists for functional purposes. All during the course of
the nation's history, governmental functions have been transferred -
from one agency to another. To have a rule of construction which
would obviate the transfer of functions from one agency to another
would merely thwart all efforts to improve government."
25
i
ii■ IIiIIIIIIiUIII 11101 ■
The )urt responded to the argument that the repeal
was a valid exercise of the police power in the interest of
mass transportation. energy conservation, and environmen-
tal protection:
"'Vet the Contracts Clause limits otherwise
legitimate exercises of state legislative authority.
and the existence of an important interest is not
always sufficient to overcome that li►nitation.. . .
:Moreover. the scope of the state's reserved power
depends on the nature of the contractual
relationship with which the challenged law con-
flicts.-
97 S.Ct. at 1517.
The Court concluded that the statute could not stand i
there were available less drastic alternatives:
". . . it cannot he said that total repeal of the
covenant was essential: a less drastic modification
would have permitted the contemplated plan
without entirely removing the covenant's
limitations. . .
97 S.Ct. at 1522.
The interpretation of Chapter 712 rendered by the
courts below is clearly not necessary to achieve title
security.
4. Respondents Cite Nothing To Support The
Holdings Of The Courts Below That Chapter
712 Extinguishes The City's Ownership. As
20
Mil
i1E1111iiill
111111111111
1111111111111111
1111
An Agency Of The State. O_I{tis
Sovereignty land
Chapter 712 expressly exempts from its provisions:
"any right, title or interest of the United States,
Florida or any of its officers, hoards, commis-
sions. or other agencies reserved in the patent or
deed by which the United States. Florida or any
of its agencies parted with title."
Fla. Stat. § 712.(t4.
It has been held that the Act can in some instances ex-
tinguish governmental ownership of land. hut only that
which has been conveyed away from the State without
reservation. Odom v. D'ltona Corporation. 341 So.2d 977
(Fla. 1977): Sawyer v. .tfodrall. 286 So.2d 610 (4th Fla.
f)CA 1973). It has not been and cannot he held that the Act
extinguishes governmental ownership of land which has
never left the State or its agencies in the first instance.
The State has parted with title only once — conveying
it to its agent the City of :Miami "for municipal purposes
only." The City of Miami has never parted with title. The
City's title cannot he extinguished by the Act.
The land in question is sovereignty land. The State of
Florida accepted this land from the United States, upon ad-
mission to the Union. subject to a trust for the benefit of the
people of the State.
The State cannot alienate this land in a manner incon-
sistent with this public trust. A general act, such as Chapter
712, cannot be construed to divest sovereignty lands in
favor of a wild deed.
21
UIIII III III IIIIIiIII IIO
111)
"The state cannot abdicate general control over
the (ands under navigable vv-aters within the state.
since such abdication would be inconsistent «ith
the implied legal duty of the state to preserve and
control such lands and the waters thereon and the
use of them for the public good..'
State ex rel. Ellis v. (ierhini,', 47 So. 353. 355 (Fla. 19O ).
Nlindful of this public trust. Florida courts and others •
))ate scrutinized purported conveyances of sovereignty.
lands.
In Odom 1)eltona. this Court held that where the Trustees fttr the
Intetn.tl Improvement Fund (Till:), under authority of the Swamplands,xct<
purported to convey away sovereignty land «hose nature %vas such as not to im-
port notice of navigability. the TI1F would he barred after 30 years by Chapter
712 1(01n challenging their oven conveyance. This Court said, however. that the
result would he different "in the case of a large Lake. such as Lake
Okec.hohce." In such a case. Chapter 712 would not preclude a challenge to the
urauthorited conveyance.
in 1-ntted Slates v. 2.) 49.17 Acres of Land. Etc.. 269 F Supp. 903
1.1a 19o-), the TI11 had purported to convey sovereignty lands at a tune when
they had no such authority. [ he court held that the grantees thereby did not
have title
"If, by mistake or otherwise. sales or conveyances arc made by the
i rustees (lithe Internal Improvement Fund of sovereignty lands . . .
such sales and conveyances are ineffectual for lack of authority from
the State.
Sec also lints v. Bowman. 41 So.2d 795, 799 (Fla. 1957) ("Basically it is trust
property and should he devoted to the fulfillment of the purposes of the Trust.
to vvtt. the service of the people."): Pembroke v. Peninsular Terminal Co.. 108
F:a. 46. Ion So. 249 (Fla. 1933).
t. Mcknight v Broedeli. 212 F.Supp. 45 (L.i). Mich. 1962):
"The title of the state to submerged lands in the Great Lakes is
impressed with it trust for the benefit of the public. The state has a
duty to protect that trust and may not surrender the rights of the
people thereto."
22
11111 111■I
IIIIIIIIIIIIIIIIIIIIII
IIII
III
II
II
II
111111
111
1111
111111
III
in the instant case. the State has not even purported to
coney away these sovereignty lands. Nevertheless, the
courts helot, the language of §712.04 notwithstanding,
have interpreted Chapter 712 to validate a wild deed and to
extinguish governmental ownership in sovereignty lands.
That this is not the last is made clear by this Court's
opinion in Odom t. Deltaic: Corp., 341 So.2d 977 (Fla.
1977). That l:ame holds that —when the State conveys land
which is not noticeably navigable to private citizens without
reservation clt public rights —Chapter 712 applies. Justices
Sundherg. Overton and England dissented, opining that the
Act should not apply even in that situation. And Mr.
Justice Boyd, writing for the Court, noted that the result
ould he different "in the case of a large lake, such as Lake
Okeechobee.- Governmental ownership of such land is not
extinguished by Chapter 712.
St. Joe misreads this Court's holding in Odom. argu-
ing that because the State convened the land to the City in
1919 and St. Joe then took a wild, void deed to the same
land in 1944. the City in 1975 could not quiet title. Odom
sloes not support this. At most. Odom holds that if the City
or State purported to convey property in 1944 to private
grantees, State authorities cannot, by the terms of the Act,
quiet title by proving that their predecessor authorities in
1944 acted without authority. When it conveys land the
State is subject to the Act. But even this is subject to the im-
portant exception discussed above ("notice of
navigability.), which is studiously ignored by the briefs of
St. Joe and Mr. Harris.
Therefore, under Odom. even if the City or the State
had purported to convey the lands in dispute to St. Joe, the
City could nevertheless maintain an action to quiet title if
23
i
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11111111
III IN
1111111
IIIIIIIIIIIIII■IIIIIIIIIII
11111111111111
111111111111111111111111 ■
the prior purported State conveyance were for some reason
voidable —St. Joe is charged with notice of the navigability
of Biscayne Bay.
in this case there is not even such a purported con-
veyance out of the State. The State and its agencies have
never parted with title. The City's ownership is therefore
protected from extinguishment by Fla. Stitt. §712.04.''
St. Joe and fir. Harris argue that the express language
in the legislative grant limiting use by the City to
"municipal purposes only- does not constitute a reserva-
tion by the State within the exception in § 712.0-I. This argu-
ment is irrelevant as well as incorrect." Mr.- Harris urges
Si Joe al•.a misreads Justice Sundhctg's dissenting opinion that the Act
cannot extinguish the States interest in siwereienty lands. St .Joe refers to
Justice Sundherg's point that the effect of;ipplxtng Chapter 712 to the facts in
Oi„rr, a, to altcnate submerged land held by the Trustees of the Internal
Ittthrouement 1-and absent the requisite safeguards of statutory notice and hear-
ing. St Joe then offers the following distinction:
"In the case at bar, by virtue of the fact that the comeyancc from the
State to the City of Miami was caused by the legislature's enacting a
special statute. such requisite safeguards of public notice and hearing
obviously were met." (St. Joe's brief. page 8.)
The City would respectfully submit that St. Joe has missed the point. No one. -
iertatnly not the City of Miami, is challenging the conveyance of sovereignty
•
lands from the State to the City of Miami. Justice Sundherg's point is that it is
constitutionally impermissible for the State to convey submerged lands way -
frunt the State without the requisite safeguards. It therefore cannot he held that
state Legislation (i.e . Chapter 712) by implication extinguishes the ownership of
the Slate's agent in this sovereignty land. The piracy of sovereignty land
through recordation of a wild deed is wholly inconsistent with the public in-
terest.
:; Die State of Florida is not directly in ',his litigation protecting its
property interests in this land. The Court is not called upon to determine what
rights and remedies the State of Florida would have against St. Joe if the deci-
sion of the courts below is upheld. However, acceptance of the St..toc and Har-
ris position would result in the alienation of an inalienable trust. See }(ayes v.
Bowman, 91 So.2d 795 (Fla. 1957); Pembroke v. Peninsular Terminal Co.. 108
Fla. 46. 146 So. 249 (1933); United States v. 2.899.17 Acres of Land, Etc., 269
F.Supp. 903 (M.D. Fla. 1967). See also. McNight v. Brocdcll, 212 F.Supp. 45
(E.D. Mich. 1962).
24
.Satt•te_'r v. ;tfodrall, 286 So.2d 610 (4th Fla. DC A 1973),
cert. denied. 297 So.2d 562 (Fla. 1974) as support. The
court in that case held that there is no implied reset vation
when the State conveys sovereignty land. But Sawyer did -
nut involve a conveyance by the State with an express use
restriction.
The importance of the use restriction in the present
case is that it establishes that the City in its ownership' of
this land is acting as an agency of the State. St. Joe at-
tempts to distinguish the agency cases cited in the City's
stain brief h\ arguing that they
. . are not in point because they relate to
governmental functions that have been expressly
delegated to cities for implementation and do not
pertain to proprietary or land title matters where
cities compete with their citizens and taxpayers on
equal basis under the law." (St. Joe's brief, page
13.)
Mr. Harris adopts the same argument.
'T'he legislative grant "for municipal purposes only"
preserves the public trust in which the State held the lands,
and reflects the legislative realization of the limitations on
its power to alienate these lands. The City in its ownership
of this land is performing a governmental function express-
ly delegated to it by the sovereign.,
See Athury v. C cntral and Southern Florida Flood Control District, 9t)
So.2d 24s, 252 (3d Fla. DCA 1957):
"Government exists for functional purposes. All during the course of
the nation's history, governmental functions have been transferred
from one agency to another. To have a rule of construction which
would obviate the transfer of functions from one agency to another
would merely thwart all efforts to improve government."
25
I
i
i
I
I
111
Fatted wIuI this agency relationship, St. Joe and Mr.
Harris irgue that because Chapter 712 at other points
refers to "political subdivisions." and because other
statutes use the word "municipalities." the exclusion of this
term from §712.04 establishes that a political subdivision
cannot be an agency of the State.' What the language of
§712.04 in fact indicates is that the legislature did nut in-
tend an all-inclusive list of governmental entities whose in-
terests are protected. Such protection is determined by
whether the entity is functioning as an agent of the State.
As the case lax discussed in the Citv's main brief es-
tablishes. a City, when performing a State function. is an
agent of the State. The use restriction imposed by the State
upon the City delegated to the City the State function of
preserving the interest of the people of Florida in sub-
merged lands.
• t he leading mof.iern commentator on statutory construction puts this
"expressio unis" argument in perspectite.
"Soeral Latin maxims masquerade as rules of interpretation while
doing nothing n,o:e. than describing results reached by other means.
1 he hest example is probably t1pressiu unius est etcfusiu afte•rius,
µhigh is a rather elaborate, mysterious sounding, and anachronistic
µat of describing the negative implication. Far from being a rule, it
is no: cten lexicographically accurate. because it is simply not true.
eci..crall!, that the mere express conferral of a right or privilege in
one kihd of situation implies the denial of the equivalent right or
prrile e in other kinds. Sometimes it does and sometimes it doe:
not. and whether it does or does not depends on the particular cir-
cumsti.r..cs of context. Without contcxival support. therefore. there
is not e%en a mild presumption here. Accordingly. this maxim is at
best a description. after the fact. of what the court has discovered
from context "
Dickerson, 1 he Interpretation and Application of Statutes. pages 234-235
(1975).
And cf. Florida Statutes §20.03(I1) (1974) defining "agency" as "an of-
ficial. officer, commission, authority, counsel, committee. department, division,
bureau. board. section. or other unit or entitt of government.- [emphasis sup-
plied]
26
5. The Trial Court Improperly .t•fade .1 tactual
!)eterntination 0J Estoppel
St. Joe contends that the trial court made no factual
determination of estoppel. Judge Harvie Duval did indeed
make the disclaimer quoted by St. Joe in its brief —the trial
judge himself must have known that to rule on the basis of
estoppel was reversible error. The trial judge nevertheless
freely expressed his opinion on the issue.
"TI IL COURT: Gentlemen, I frankly think that
712 is applicable. If it was not applicable, 1 think
that the deeds and such in the past are good deeds,
and probably the Act of 1922 Isicl cures that, and
if all of that was not there, if anybody has ever
been estoppcd or waived any rights —the City of
Miami has been sitting here with this land having
been filled hack in the 20's. i would have to take
judicial knowledge that they have been getting
taxes on all of it. all of this time. It is given or in-
dicated as owned property. There has never been a
protest of any kind.
Under your argument, we could he trying this
case 100 \'ears from now and say that the City
owns some property. That is kind of like going
hack to the Indians and Manhattan. C am going to
dismiss it with prejudice."
The implicit decision of estoppel is both procedurally
infirm and substantively incorrect!'
In State v. Zimnng. 566 P.2d 725 (Hawaii 1977), in quieting title in the
state to land formed by a volcanic eruption extending the shoreline, the court
held the state was not estopped by collecting taxes on the property and remain-
ing silent when the land was leveled and landscaped.
27
Furthermore, the grantee of a wild deed may not he
heard to argue that the true owner is estopped from clearing
title. St. Joe must he charged with notice in 1944 that FEC
did not own the land. and that the land was sovereignty land
held by the City in trust for the people of Florida. This
Court held in Price t'. Stratton. 45 Fla. 535, 33 So. 644. 647
(1903).
"the rule applies only where the title is not equally
open to the parties, and in favor of one who would
be mislead by want of notice of the adverse right.
It is essential to the application of the doctrine of
estoppel that the party claiming the estoppel must
have been not only destitute of knowledge of the
true state of the title, but also of any convenient
and available means of acquiring such knowledge.
Where the condition of the title is known to both
parties or both have the same means of ascertain-
ing the truth. there is no estoppel.
\11 of the Respondents took title to the City's kind
before the enactment of Chapter 712. They were on notice
of the City's ownership. They had no marketable record ti-
tles act to rely on to believe that they had good title. There
has been no reasonable reliance, only hope (or calculated
risk).
"[O]ne's own wrongful act ordinarily cannot serve
as a basis of a claim of estoppel against another.
and it can he applied as an estoppel against estop-
pel.—
'Trice is follo«ed in Overstreet v. Bishop. 343 So.2d 958 (1st Fla. DC,\
1977).
2g.
i
111
111111■ IIIIII1111111IIII
11111
111111111111111111
Jefferson National Bank at Sunny Isles t'. Aro Dade
County, 271 So.2d 207, 214 (3d Fla. DCA 1972?.
Not only did the trial court reach an improper conclu-
sion that the City is estopped to quiet title, the City was
improperly denied the opportunity to plead and prove that
the Respondents are estopped to rely on Chapter 712.
1
111
111
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II
II
i
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I
I
CONCLUSION
The City brought this suit to quiet title to sovereignty
lands granted to it by the State in 1919. in 1944 Florida
East Coast I lotel Corporation gave a deed to St. Joe pur-
porting to convey the land to St. Joe. That deed was wild
and therefore void.
The courts below have held that the City's ownership is
extinguished by the Nlarketahle Record Titles Act. That
holding should he reversed.
Chapter 712 was not intended and should not he con-
strued to divest a feeholder in favor of a wild deed. Such a
retroactive validation would he inconsistend with the basic
principles of property law and with the constitutional
protections of vested property rights.
Nor was Chapter 712 intended to extinguish
governmental ownership of sovereignty lands. Section
712.04 expressly exempts such ownership. Odom expressly
preserves such interests.
Florida became State under the condition that it hold
such land in trust for the public. Neither it nor the City ever
had the power or authority — by act or omission — to al-
low others to steal the land. When those others were on
legal (as well as, in all probability, actual) notice of the
11
public trusteeship of that land, both law and equ compel
a ruling that the land belongs to the people.
Respectfully submitted..
LAW OFFICES
(GUY 13. BAILEY. SR.
Attorneys for Petitioner
Suite 1820, One Biscayne lower
Two South Biscayne Boulevard
Miami, Florida 33131
Guy B. Bailey.
1
•
AERTIFICATE OF SERVICE
WE IIERFI3Y CERTIFY that a true copy of the
foregoing Petitioner's Reply Brief was mailed to Shutts &
Bowen. 1000 Southeast First National Bank Bldg.. Miami.
Honda 33131: Sibley, Levenson & Glaser. P.O.
Bo‘ 390360. Miami Beach. Florida 33139: Steel, IIector &
Davis. 1400 Southeast First National Bank 131dg., Miami,
Florida 33131: and Russo, Van Doren & Allen, P.A.. 465
Ponce de I.eon Boulevard. Coral Gables. Florida 33147:
this 29th day of August. 1977.
,
1111111E11
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1111 111 111111111
iiiiii111 uuiii.l■u..1 i •
iu the
f4tupreme Cutrt ofoeia
CASE NO. 5t, 775
CITY OF MIAMI,
a Florida municipal corporation„
Petitioner,
vs.
ti'I'..1OE PAPER COMPANY..
a Florida corporation;
SOUT1IEAST PROPERTIES, INC.,
a Florida corporation;
I Ina!' E. NIATI I ESON, .1R.. individually; and
SALLY S. UOMMERI('H, formerly
Sally S. NIatheson, individually.
Respondents.
I'ETITIONER'S BRIEF ON THE. MERITS
LAW OFFICES
GUY R. BAILEY..JR.
Attorneys for Petitioner
1820 One Biscayne Tower
Miami, Florida a:il:ll
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CITATIONS OF AUTHORITIES
Case
Alden v. Pinney
12 Fla. 348 (1869)
Banana River Props. v. City of Cocoa Beach
287 So.2d 377 (4th Fla. DCA 1974) ..... •. •.. • 3
Biltmore Village. Inc. u. Royal Biltmore Viltage;
Inc.
71 So.2d 727 (Fla. 1954) 21, 24.27
Blankner v. City of Chicago . 26
504 F.2d 1037 (7th Cir. 1974) .....
Board of Com'rs. of Everglades Drainage Dist. v.
Forbes Pioneer Boat Line
86 So. 199 (Fla. 1920), rev'd on other grounds, 23
258 U.S. 338
Board of Education v. Miles
207 N.E.2d 181 (N.Y. 1965),
Brault v. Town of Milton
527 F.2d 730 (2d Cir. 1975) _.. ��--
Brickell v. Trammell, 36
82 So. 221 (Fla. 1919) •�•�4 - •-*4��4,
-
Broward v. Mabry
50 So. 826 (Fla. 1909) . _ ..
1.11
I Main
I
i
1111
1111
111111111111111111
111E111
111111111111111111111111111
('ase
Duck c. Mouradian.
100 tio.2d 70 (3d Fla. DCA 1958)
Buck r. Triplett
32 Su.2d 753 (Fla. 1947) ...........
Campbell v. Horne
3 ti0.2d 125 (Fla. 1941) ...............
Chicago 13 & Q Ry. v. Chicago
166 U.S. 226, 17 S.Ct. 581, 41 L.Ed. 979 (1897) :
rio of Miami V. Lewis
104 So.2d 70 (3d Fla. DCA 1958)
Page
19
('►auk V. Carlson
364 F.Supp. 24 (D. S.D. 1973) .
Cornish r. Kinder Canal Co.
267 So.2d 625 (La. App. 1972)
Cox t'. Holder
3•15 So.2d 846 (1st Fla. DCA 1977
C'reary c'. ('reary s Estate
:338 ,o.2d 26 (1st Fla. DCA 1976)
Croft v. Young
188 So.2d 859 (1st Fla. DCA 1966) .
Empire State Insurance Co. v. Chafetz
302 F.2d 828 (5th Cir. 1962)
�►
Page
Case
Exchange National Bank v. Lawndate
243 N.E.2d 193 (Ill. 1968) ................ 13,. 14
Franklin Life Ins. Co. v. Tharpe
179 So. 406 (Fla. 1938) .....
---�-
Hayes v. Bowman
91 So.2d 795 (Fla. 1957) .....
H.K.L. Realty Corporation v. Kirttey`
74 So.2d 876 (Fla. 1954)
In Re Brown's Estate
117 So.2d 478 (Fla. 1960) ... .
Indiana ex rel. Anderson v. Brand
30:3 U.S. 95, 58 S.Ct. 443, 82 L.Ed. 685 (193&)1 2a
Jefferson National Bank at Sunny Isles v. Metro
Dade County
271 So.2d 207 (3d Fla. DCA 1972) cert. denied,
277 So.2d 536 37, 38
Kaufman v. City of Tallahassee 31
94 So. 697 (Fla. 19'
L. C. Morris, Inc. v. Allison
277 So.2d 28 (3d Fla. DCA 1973),: appeal after
remand, 309 So.2d 9 (3d Fla. DCA 1975) .... 36
Loeb v. City of Jacksonville _ 31
134 So. 205 (Fla. 1931) -- --
19!
1
29
.�.. �. 29
pm" 11
Case
0
Mahood v. Bessemer Properties, Inc.
18 So.2d 775 (Fla. 1944) .......
!Hann V. (Goodyear T & R Co.
300 tio.2(1 6titi (Fla. 1974) .......
Marshall v. Hollywood, Inc.
236 So.2d 114 (Fla. 1970)
Martin v. Busch
112 So. 274 (Fla. 1927)
McConville v. Ft. Pierce Bank & Trust Co.
135 So. :392 (Fla. 1931) ............ _.
McCord v. Smith
4:3 So.2d 704 (Fla. 1950)
Missouri Pacific Ry. Co. v. Nebraska
164 U.S. 40:3, 17 S.Ct. 130, 41 L.Ed. 489 (1896)
Moyer v. Clark
72 So.2d 905 (Fla. 1954)
Mullane v. Central Hanover Bank & Trust Co
3:39 U.S. 306, 70 S.Ct. 652, 94 L.Ed. 865 (1950)18,20
Murrison v. Fenstermacher
203 I'.2d 160 (Kan. 1949) 2
Odom v. Dcltona Corp.
341 So.2d 977 (Fla. 1977)
iv
:r =a5;li
lk
111111III IIII
III111111III
Case
11111111111111
11
111111111111111
Patton v. Los Angeles
206 Cal. 662 (1929}
11
11
Pearce v. Cone
2 So.2d :360 (Fla. 1941)- .
Pembroke v. Peninsular TerminaE' Ccr.
146 So. 249 (Fla. 19:33)
11111111111111111111111111111111.111
Poladian v. Johnson
85 So.2d 140 (Fla. 1956)
Price v. Stratton
33 So. 644 (Fla. 1903) .
Reed v. Fain
145 So.2d 858, 870 (Fla. 1962)
Page
32
32:
38,
Reid u. Bradshaw 29
302 So.2d 180 (1st Fla. DCA 19744 .. ....•.. • .
Schneider u. Dist. of Columbia �6
117 F.Supp. 705 (D. D.C. 1953) _..__k-• -•
Shavers u. Duval County .�4
7:3 So.2d 684 (Fla. 19541, . _ . � ......... • - _ ... .
Smith Bros. v. Williams
131 So. 335 (Fla. 1930) .... . =w ."-••. -• 12, '20
Sotomura v. County of Hawaii '�6
402 F.Supp. 95 (D. Hawaii 19t15)) ...�.---.-..
v
i
i
i
Case
State v. Black River Phosphate Company
13 So. 640 (Fla. 1893)
State v. City of Auburndale
85 So.2d 611 (Fla. 1956)
State Dept. of Highways v. Tucker
170 So.2d 371 (La. 1964)
Thiesen v. Gulf, F & A Ry. Co.
78 So. 491 (Fla. 1918)
Trustees of Dartmouth College v. Woodward
17 U.S. 518, 4 L.Ed. 629 (1819)
T.I.I.F. v. Claughton
86 So.2d 775 (Fla. 1956) 10, 32, 38 ,
Page
9
1
Turk v. Richard 31
47 So.2d 543 (Fla. 1950)
Walton County v. Board of Public Instruction of
Walton County
161 So.2d 45 (1st Fla. DCA 1964)
Waterman v. Smith
94 So.2d 186 (Fla. 1957)
Wernle v. Bellemead Development Corp.
308 So.2d 97 (Fla. 1975)
West v. Town Lake Placid
120 So. 361 (Fla. 1929)
vi
114
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A
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IIIIIIIIIIIII
11
II 1
11
11
11
Case
Whaley v. Wotring
225 So.2d 177 (1st Fla. DCA 1969).—..—
Page
17
Wichelman v. Messner 1i3, I`5
83 N.V. 2d 800 (Minn. 1957)
Wilson v. Kelley 17.
226 So.2d 123 (2d Fla. DCA 1969) ....»...�:��--
Wright v. Blocker
198 So. 88 (Fla. 1940) ....
12
Yamaha Parts Distributors, Inc. v. Ehrman K « 24, 2
316 So.2d 557 (Fla. 1975) - --
viu
•11A
OTHER AUTHORITIES
41 A.L.R.2d 1384
25
55 A.L.R.2d 554
1 Boyer Florida Real Estate Transactions §14.15
(1976) 14
Florida Constitution, Article I, 10 24
Florida General Laws, Ch. 791§ 2 (1856) (repealed)
("The Butler Act") 11, 36
Florida Statutes 6.01 9
Florida Statutes §20.03(11) (1974) 31
Florida Statutes Chapter 712 .. 3, 7, 12, 17, 18,19, 20,
21, 22, 2:3 29, 32, 33
Florida Statutes § 712.01(2) 14
Florida Statutes §712.01(3) 14
Florida Statutes §712.02 13, 14
Florida Statutes § 712.03(1) 1,47
Florida Statutes § 712.04 3, 30, 31, 32, 33, 34
'Model Marketable Record Titles Act 32
Session Laws of the State of Florida, Chapter 8305
(1919) 4, 33
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U.S. Constitution, Article I, §10,, CI.1 23,, 24
U.S. Constitution, Amendment XIV I8,, 26
. . .
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TABLE OF CONTENTS
Page.
STATEMENT OF THE CASE
STATEMENT OF THE FACTS ........
QUESTION PRESENTED
«'HETHER 1'I' WAS ERROR TO DIVEST:.
"I'HE ('I'I'Y OF ITS VESTED GRANT OF:
SOVEREIGN"I'Y LAND BY RETROSPEC-
TIVE VALIDATION OF A WILD DEED....
ARGUMENT
WHERE FLORIDA GRANTED
SUBMERGED SOVEREIGNTY LAND TO
"I'HE (TI'Y. EXPRESSLY PRESERVING
THE LAND'S PUBLIC CHARACTER BY
USE RESTRICTION, IT WAS ERROR TO
I)IVES1' THE CITY OF SUCH LANDS BY
A('('ORI)ING RETROSPECTIVE VALIDITY
To A WILD DEED TO A PURPORTED
PRIVATE OWNER.
1. The Private Interests "Title" To The
Land in Questiwz Derives From A Wild Deed
Which Is Therefore Void.
2. 7'he Act Cannot Divest The City of Its
Vested Property Rights 1'2
(a) Chapter 712 Does Not Apply To A
Wild Deed.
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(h) A Wild Deed Is Not A "Root of Title"
As Defined By The Act. 13
(c) The Inapplicability of the Act to=Wild
Deeds Is Supported by Textual Authorities
And By Decisions In Other Jurisdictions
(d) Marshall v. Hollywood Does Not
Hold The Act Applicable To Wild Deeds. 16
3. As Interpreted Below, The Act Is Uncon-
stitutional 17
(a) The Act As Interpreted Below
Deprives Vested Owners of Property Without
Due Process of Law In Violation Of The
Fourteenth Amendment. 18
(b) Retroactive Application Of The Act
Deprives Vested Owners of Property Without
Due Process of Law. 21
(c) As Interpreted Below, The Act Im-
pairs The Obligations Of Contract. 23
(d) The Decisions Below Constitute An
Unconstitutional "Taki -ig" Of Property . 25
(e) Other .Jurisdictions Hold Similar
Legislation Unconstitutional Or Construe It To
Avoid The Constitutional Problems Created
Below. 27
xi
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IIIIIII
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(f) Prior Florida Decisions Do Not Sup-
port The Constitutionality Of The Act. 29
4. The Act Specifically Exempts An Agency
Of The (Government, Such As The City of
Alianzi, From Its Operation '30
5. It Was Error To Alake A Factual Deter-
mination Of Estoppel In A Hearing Without
Evidence On A Motion To Dismiss 35-
CONCLUSION
CERTIFICATE OF SERVICE
Jtt tie
'uprente (taut of J1 tia
CASE NO.. 51, 77.5
CITY OF MIAMI,
a Florida municipal corporation.
Petitioner,
VS.
ST. JOE PAPER COMPANY,.
a Florida corporation;
SOUTHEAST PROPERTIES, INC.,
a Florida corporation;
HUGH E. MATHESON, .IR., individually; and
SALLY S. DOMMERICH, formerly
Sally S. Matheson, individually,
Respondents.
PETITIONER'S BRIEF ON THE MERITS
i
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STATEMENT OF THE CASE'
The Certified Question
This is the City of Miami's petition based upon the
Third District's Article V, > 3(h) (3) certification of the -
tollowing question:
Whether The Zlarketahle Record Titles Act Is
Constitutionally Applied When It Is Held To
Prevent The Claim Of A City Under A
Statutory Land Grant From The State
Granting The City All Of The State's Rights
'I'o Submerged Land Including Water -Front
And Riparian Rights.=
The Trial Proceedings
The City sued to quiet title and to eject St. Joe from
10.69 acres of extraordinarily valuable, downtown,
bayfront land which was part of a specific statutory
grant to the City in 1919.
St. Joe obtained a dismissal with prejudice from
then Circuit Judge Harvie DuVal, whose expressed basis
Petitioner. City of Miami. was plaintiff and appellant below. Respon-
dents, St. .hut Paper Co.. et al.. were defendants and appellees. Parties will
be called by name or as they stood in the trial court. Respondents will
sometimes collectively be called "St. Joe." The appellate court below, the
Court of Appeal, 'Third District of Florida, will he called "the Third
District.' The Circuit Court in and for the Eleventh Judicial Circuit, Har-
vie 5. DuVal, .1., will he called "the trial court." The Marketable Record
Titles Act. F.S. Chapter 712. will he called "Chapter 712— or the 'Act. '
=The City's petition is, of course, not limited to the question. See peti-
tion at A. 199.
2
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was a factual finding of estoppel and who:mplicit rul-
ings were that St. Joe's acceptance of a wild deed in 1944
was constitutionally cured by a retroactive application
of Chapter 712 and that that act applied despite
§712.04's express exemption of state agencies (the City's
status here) from its purview.
Appellate Proceedings
The Third District basically ruled that Marshall v.
Hollywood Inc. s.' dictum on wild deeds and Odom v.
Ueltona Corporation's.' dicta on sovereignty lands and
Chapter 712 gave it reason to affirm, but it certified the
quoted question to this Court.
'236 Sold 114 (FIa., 1970)t.
4341 Se.2d 977 (Fla.. 1977)0..
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STATEMENT OF THE FACTS
In 1845, by act of Congress admitting Florida to the
union, the United States conveyed to the State all right,
title and interest in lands under navigable waters, and
within or about its shores "in trust for the benefit of the
people of Florida.''
On .lane 2, 1919, by special act, Florida's legislature
conveyed the submerged lands (and other land) to the
('ity of Miami, reserving its interest in having the
sovereignty land remain public by imposing upon it the
requirement t hat it he used in perpetuity, "for
municipal purposes only.' There is no other con-
veyance of this land out of the State from 1845 to 1977.
In 1898 Henry Flagler conveyed 14 acres of upland
property to Florida East Coast Hotel Corp.' Flagler
owned no riparian rights in the adjacent submerged
lands. In the 1920's and later, FEC illegally filled and
Florida's statutory grant to Miami was subject only to two exceptions:
,at prior grants. and (10 existing riparian rights of upland owners. Since
there had been no prior grants and were no existing riparian rights, as to
the land in dispute, the exceptions were meaningless.
Florida's statutory grant to Miami for municipal purposes only was
otherwise absolute: the legislature expressly repealed "all laws and parts of
laws- which conflict with the grant.
Now known as the Flagler System, hereafter "FEC."
Before 1921, owners of upland riparian lands had no rights in the
foreshore other than their common law riparian rights in the nature of ease-
ments (i.e., ingress, egress, fishing, bathing, etc.) except in the moat un-
usual and extraordinary circumstances. It was settled law that one as-
serting a claim to such lands did so in the face of the state's presumptive
ownership. Thiesen v. Gulf, F & A Ry. Co., 78 So. 491 (Fla. 1918): Brickell
v. Trammell, 82 So. 221 (Fla. 1919).
4
bulkheaded part of the City's submerged land and, in
1944, FEC purported to convey to St. Joe the 14 original.
acres and the filled land. The putative 1944 conveyance
also purported to convey 4.24 acres of unfilled land
("Tract B") denominated as a yacht basin. In 1949, St.
Joe filled the yacht basin property; but no deed purports
to convey that area as filled land at any time.
Thereafter, St. Joe purported to convey portions of the
property to the other defendants or to their predecessors
in claimed interest.
In summary: (a) the City's title chain is as follows:
U.S --+-Florida—'City.
(b) St. Joe's "chain of title" springs into being with
the wild deed of 1944.
I I
r QUESTION PRESENTED
WHETHER IT WAS ERROR TO DIVEST
THE ('I"1'Y OF I"I'S VESTED GRANT OF
SOVEREIGNTY LAND BY RETROSPEC-
TIVE VALII)A'I'ION OF A WVILD DEED.
Ins. .`�++,
_.r;=,...a .._ .. ,.r. :; a'wti c�;,r���.w <<sn,: v�V,.�'__•'";;Y�µ�si
11111111111111111111111Misim
ARGUMENT
WHERE FLORIDA GRANTED
SUBMERGED SOVEREIGNTY LAND TG
THE CITY, EXPRESSLY PRESERVING
THE LAND'S PUBLIC CHARACTER BY
USE RESTRICTION, IT WAS ERROR TO
DIVEST THE CITY OF SUCH LANDS BY
ACCORDING RETROSPECTIVE VALIDITY
TO A WILD DEED TO A PURPORTED
PRIVATE OWNER.
1. The Private Interest's "Title" To the Land in Ques-
tion Derives From a Wild Deed Which Is Therefore
Void.
2. The Act Cannot Divest The City of Its Vested
Property Rights.
(a) Chapter 712 Does Not Apply To A Wild Deed.
(b) A Wild Deed Is Not A "Root of Title" As
Defined By The Act.
(c) The Inapplicability of the Act to Wild Deeds Is
Supported by Textual Authorities And By Decisions In
Other Jurisdictions.
(d) Marshall v. Hollywood Does Not Hold The
Act Applicable To Wild Deeds.
:3. As Interpreted Below, the Act Is Unconstitutional.
(a) The Act As Interpreted Below Deprives Vested
Owners of Property Without Due Process of Law In
7
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Violatio,• it The Fourteenth Amendment.
(b) Retroactive Application Of The Act Deprives
Vested Owners of Property without Due Process of Law.
(c) As Interpreted Below, the Act Impairs The
Obligations of Contract.
(d) The Decisions Below Constitute An Uncon-
stitutional "Taking" Of Property.
(e) Other
Jurisdictions Hdl Similar
Legislation
Unconstitutional ctrueItfoAv�idTheCon-
stitutional Problems Created Below.
(f) Prior Florida Decisions Do Not Support The
Constitutionality of the Act.
•a. The Act Specifically Exempts An Agency of The
Goc'ernmcnt, Suclz As The City of Miami, From Its
Operation.
5. It lVas Error To Make A Factual Determination Of
Estoppel In A Hearing Without Evidence On A Motion
To Dismiss.
ARGUMENT
WHERE FLORIDA GRANTED SUBMERGED
SOVEREIGNTY LAND TO THE CITY, EX-
PRESSLY PRESERVING THE LAND'S-
PUBLIC CHARACTER BY USE RESTRIC-
TION, IT WAS ERROR TO DIVEST THE
CITY OF SUCH LANDS BY ACCORDING
ItE'I'ROSPEC"aIVE VALIDITY TO A WILD
PUR PURPORTED PRIVATE
TO TE
OWNER.
1. The Private
eFt's "Title" To The Land
m A Wild Deed Which Is
In Question Derivesro
Therefore Void.
The only title to the land in question traceable to the
sovereign is in and to the City of Miami.
Title to all lands under navigable waters has its
origin in the United States. In 1845, the United States
conveyed this title to Florida "in trust for the benefit of
the people of Florida." The State specifically accepted,
acknowledged and ratified this trust. F.S. § 6.01 (1845).
Title to such land is, therefore, held by the State
subject to this inalienable trust. The 1968 Florida Con-
stitution also expressly recognizes this trust.' Prior to the
1968 Constitution and to the Florida statute, this trust
was recognized as a matte: of common law.' Even
^Fia. Const. Art. X, ;ill (1968).
"Hayes v. Bowman, 91 So.2d 795 (Fla. 1957); Browardv. Mabry, 50 So.
826 (Fla. 1909); State v. Black River Phosphate Company,13 So. 640 (Fla.
1893); Alden v. Pinney, 12 Fla. 348 (1869).
9,
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.rinteeslienn the State take with notice that lands under
obviously navigable waters are "sovereignty lands"sub-
ject to this inalienable trust. This Court acknowledged
this concept earlier this year in Odom v. Deltona Corp.,
:341 So.2d 977 9S8 ( Fla. 197 7) :
-Appellants also argue for the application of the
'notice of navigability' concept. i.e., that the
grantee of swamp and overflowed lands under a
Trustee deed takes with `notice' that the con-
veyance does not include sovereignty land. In
the case of a large lake, such as Lake
Okeechobee, a 500,000 acre lake, we agree."
(emphasis supplied)
Biscayne Bay and the Atlantic Ocean are at least as
obviously navigable as Lake Okeechobee, and Flagler,
FF.0 and St. Joe were and are all on legal notice of the
sovereign nature of this land. And they would be even if
the land had not been conveyed to another Florida public-
•
entity
The State, by statutory land grant, conveyed these -
submerged lands in 1919 to the City of Miami, imposing a
restriction of its use, in perpetuity, "for municipal pur-
poses only." The City took this property subject to this
inalienable trust, "fur the benefit of the people of
Florida.
The putative 1944 conveyance purports to transfer
from FEC to St. Joe 24.69 acres. FEC held record title to
'The validity of this grant was recognized in T11F v. Claughton, 86
So.2d 775, 784 (Fla. 19561. See also, Pembroke v. Peninsular Terminal Co.,
146 So. 249 (Fla. 19:33); Hayes v. Bowman, 91 So.2d 795, 802 (Fla. 1957). -
10
14 acres of this land, by virtue of the 1898 conveyance to
Henry Flagler. The City does not dispute respondent's
ownership of this 14 acres. As to the remaining 10.69
acres, however, the putative 1944 conveyance is a "wild
deed" — that is, one purporting to convey land which the
grantor did not own.
FEC did not own this 10.69 acres. The City did and
still does.
The 1898 deed conveyed to FEC 14 acres "together
with all and singular the riparian rights and submerged
lands appertaining thereto." This did not convey an es-
tate in anything more than the 14 acres. There were no
"submerged lands appertaining, thereto." Land does not
pass as appurtenant to land.
In the 1920's, FEC bulkheaded six acres of this
land. FEC did not thereby obtain title." The land had in
fact been previously conveyed, in 1919, to the City of
Miami.
The 1944 conveyance thus purports to convey 10.69
acres, title to which was in the City and not in the pur-
ported grantor. Any good faith title searcher must have
1{espondents argued in the courts below that they obtained title to
the submerged lands by virtue of the so-called "Butler Act." The "Butler
Act" did nut vest title to the submerged lands in the respondents. As of
1919, the riparian rights act. of 1856 di l give rights to riparian owners to
dredge, fill and bulkhead, and thereby ,o acquire title —but only to owners
of land to the !our water rnnrk. Haves v. Bowman, 91 So.2d 795 (Fla. 1957);
Thiesen v. Gulf F & A Rv. Co., 78 So. 491 (Fla. 19181. Respondents'
predecessors in title to the then -existing land owned only to the high water
mark. After 1919 the submerged lands were vested in the City. Any subse-
quent tilling to this was devoid of legal authority. Moreover, all the dis-
puted property is outside the channel which bounded even the putative
claim by P.E.C.
it
found in .f944 that the grantor had no title, or even a
colorable title, to this 10.69 acres, and that the only con-
veyance of this land out of the sovereign was to the City
of Miami, as an agent of the State and "for municipal
purposes only..,
The 1944 deed is wild and therefore void. Vet on the
basis of this void instrument the courts below have
granted the land to St. Joe and have divested the City.
2. The Act Cannot Divest The City of Its Vested
Property Rights.
(a) Chapter 712 Does Not Apply To A Wild Deed.
"1'he decisions below erroneously presume that the
Act validates a wild deed and that the 1944 wild deed is
a "root of title" vesting the property in St. Joe.
But it has always been the law that a wild deed is
void and has no effect. See, e.g., Wright t,. Blocker, 198
`0 88 (Fla. 1910). As applied by the courts below,
however, the Act does exactly that —it validates a void
instrument, in clear violation of the ancient principle
that a legislative enactment "cannot breathe life into a
corpse.- Smith Bros. t'. Williams, 131 So. 335, 337 (Fla.
Such an interpretation goes beyond the Act's in-
tended and permissible scope. For the primary purpose
of the Act is not to resolve disputes between conflicting
chains of title, but rather to free the record chain of title
"from the burdens of old conditions and
restrictions which at each transfer of the
12
property transfer with its marketabi►l. The
statute does not operate to provide the founda-
tion for a new title."
Wichelman v. Messner,
1957). To the same effect,
a. Lawndale. 24:3 N.E.2d
83 N.W.2d 800, 819 (Minn.
see Exchange National Bank
193 (III. 1968) :
"A consideration of our Act, including the sec-
tion declaring the legislative purpose of
`simplifying and facilitating land title transac-
tions by allowing persons to rely on a record
chain of title' leads us to conclude that the Act
contemplated the existence of only one record
chain of title holder. We deem that the applica-
tion of the statute in a case involving two com-
peting record chains of title as are presented
here was not intended. . . ."
The courts should therefore avoid interpreting the
act as validating a void instrument.
(b) A Wild Deed Is Not A "Root of Title" As
Defined By The Act.
The Act does not, by its terms, purport to validate a
wild deed. The Act protects persons who have "been
vested with any estate in land of record for 30 years or
more." Fla. Stat. ; 712.02. A F erson holding under a void
deed, even if of record for 30 years, has no estate of any
sort. He has never been "vested" with any interest in
land. Thus a wild deed is exempted from the protections
of the Act because it is not included within the defini-
tion of marketable title in § 712.02..
to
1111
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Before there can be a "marketable record title" un-
der § 7 12.02, there must be a "root of title," § i 12.01(2)t
which requires a "title transaction." "Title transaction"
is defined by > i 12.U1(3) as one "which affects title." A
void deed does not affect title.
Even if a wild deed could he a "title transaction," it
nevertheless would be exempted from protection by
1'?.O3(11, which provides in pertinent part that the Act
does not extinguish "defects inherent in the muniments
of title." A wild deed is inherently defective and thus
within this exception. It purports to convey ownership
by a grantor with no prior chain of title.
(c) "The Inapplicability Of The Act To Wild
Deeds Is Supported By Textual Authorities And By
Decisions In Other Jurisdictions.
1 Boyer, Florida Real Estate Transactions, 14.15
(1976), states as follows:
"The statute will not automatically result in
abstracts of title going back only 30 years . . .
an interest reflected in the root or in the
recorded chain in that time, will have to be
checked out back to its source. " [emphasis sup-
plied I
Wild deeds are not honored by other states' in-
terpretations of virtually identical acts. In Exchange
National Bank U. Lau•ndule, 243 N.E.2d 193 (III. 1968),
the Illinois Supreme Court so held:
"Were we to hold otherwise it could result in
a 'wild deed' being enabled to serve as the foun-
14
.,.
dation of a new record of chain of titi so that
it, as the more recent 40-year chain of title,
would he entitled to the benefit of the Act. This
could result in an unwelcome holding and pos-
sible constitutional complications, for it would
he then possible for the grantee of a complete
and even fraudulent stranger to title to divest
the title of a record owner, who may have
satisfied the usual responsibilities of
ownership, such as paying taxes, but who did
not file a statement of claim to preserve his in-
terest, as the statute requires. The legislature
not having so provided, we believe that it was
not intended that a chain could be founded on
a wild deed, or as one court expressed it, 'on a
stray, accidental or interloping conveyance.'
Too, the legislative purpose under the Act of
'simplifying and facilitating land title transac-
tions' would hardly be furthered by a contrary
holding. A purchaser, though he might trace
title back to an original grant from the United
States and might have examined grantor -
grantee indices, could not be assured that a
chain of title based on a 'wild deed' did not in-
dependently exist, to the prejudice of his
rights." lAt 195-196, citations omitted]
In Wichelman v. Messner, 83 N.W.2d 800, 819
(Minn. 1957), the court stated:
"We do not think the statute lends itself to an
interpretation to the effect that title may be
founded on a stray 'accidental' or interloping
conveyance. Its object is to provide, for the
recorded fee simple ownership, an exemption
15
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i
from t burdens of old conditions and restric-
tions which at each transfer of the property
transfer with its marketability. The statute
ti.,es not .tjx'rat(' to prouid(' the foundation for a
,zeu title.- lot ir19. emphasis supplied]
itl► llarshall v. Hollywood Does Not Hold The
:Act Applicable to Wild Deeds
The 'Third District. relying on Marshall e. tfol-
i held the :act applicable to wild deeds. But
t hat decision (foes not hold. or even say. that a wild deed
:(n ire root of title. it saes that a deed subsequent t() a
ow►Itl +tt•t.t1 may be a root ,:f title. In Marshall. this Court
anicni tl the Fourth Districts holding `that the Act
0,111t.•:: !ni:eke tability to a chain of title arising Out of a
,:!'ild deed so long as the strict requirements of
t he Act me met." I At 116. emphasis supplied'
Pie root of title in Marshall was not the forged
deed. 1iatlit:r, the root of title arose from a chain which
included. prior to the :30-year old root of title. a forged
deed.
"►n summary, although the . . . deed initiating
the chain of title involved here was forged, this
(ii•ed baled but one link in the chain coming
Le fore the effective root of title in this case
defined by the act. . . . 236 So.2d at 120
\loreover..tit(zrshall did not involve two conflicting -
chains of title. The deed challenged was a forgery pur-
porting to convey property owned by a corporation. The
plaintiff was the administrator of the estate of a two-
thirds shareholder in the company, appointed in 1966,
16
4:3 years after the death of the shareholder 9 43 years
after the forged deed. Unlike the City here, plaintiff -
administrator did not have a chain of title to the real es-
tate, but rather sought a decree establishing his
equitable interest in the land, as administrator of the es-
tate.
Applied here, this means only that the deeds subse-
quent to the 19.14 conveyance, by which the other
respondents obtained purported title from St. Joe, can
form roots of title as defined by Chapter 712. None of
these subsequent conveyances, however, are 30 years
o!d.
Similarly, in Whaley v. Wotring, 225 So.2d 177 (1st
Fla. DCA 1969), it was not the purported root of title
which was claimed to be wild, but rather a deed prior to
the root of title.
Wilson u. Kelley. 226 So.2d 123 (2d Fla. DCA 1969),
does state that a wild deed may serve as a root of title.
The statement is ()bite'r dictum. The court, in fact, held
against the party seeking the benefit of the Act, con-
cluding that the appellant's quit -claim deed did not
constitute a root of title.
Thus, it has not been and should not be held that a
wild deed can constitute a root of title.
:3. As Interpreted By The Courts Below, The
Act Is Unconstitutional.
As interpreted by the courts below, the Act has
divested the City of property it has owned since 1919—
sovereignty lands title to which has never left the State
17
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since acquisition upon admission to the Union.
1'he courts below have held that title to this property is
vested in private parties on the basis of a void instru-
ment executed in 1941. Such alchemy is not only incon-
sistent with the law of real property and legislative in-
tent. it is also inconsistent with constitutional protec-
tions of property rights. If the interpretation of the Act
adopted below were correct, the Act would violate both
the due process clauses and the contract clauses of the
Florida and United States Constitutions.
(a) As Interpreted Below, The Act Deprives A
Vested Owner Of Property Without Due Process Of
Law In Violation Of The Fourteenth Amendment.
The Fourteenth Amendment to the United States
Constitution provides:
"[NI() state shall . . . deprive any person of
life. liberty, or property without due process of
law......
There can be no doubt that the City has been
deprived of property by Chapter 712 as applied below. -
The he only quest ion is whether the deprivation comports
with due process. A threshhold requirement of due
process is notice "such as one desirous of actually in-
forming . . . might reasonably adopt to accomplish it."
Mullane r•. ('antral Honorer Bank & Trust Company,
l'.S.:30(i, :315, 7O S.Ct. 652. 94 L.Ed. 8(i5 (1950).
The constitutional notice requirement concerning
statutes of limitations is included in the general rule
that the statute does not begin to run until "there has
been notice of the invasion of a legal right or a person
18
has been put on notice of his right to a cause of action."
Buck v. Mouradian, 100 So.2d 70, 71 (3d Fla. DCA
1958); Franklin Life Ins. Co. v. Tharpe, 179So. 406 (Fla.
19:38).
Statutes affecting real estate, as well as valid deeds
within a chain of title may satisfy, by constructive
notice, the constitutional requirement. But as this Court
has noted in Marshall v. Hollywood, Chapter 712 is
much broader in scope than the recording statutes. The
recording statutes in effect define the requirements for
"perfecting" an interest in real estate. Such statutes are
therefore similar to those defining the formal requisites
of a conveyance —form, attestation, etc. The latter
statutes define what is a valid conveyance of real estate,
and thus in no way can be deemed a deprivation of
property. The recording statutes determine the relative
priority of conflicting, valid conveyances. They do not
purport to declare interests valid or invalid, and they do
not purport to extinguish interests. They merely es-
tablish that to secure an interest which will be good
against subsequent interests in the same real estate,
that interest must he "perfected" by recordation.
Chapter 712 attempts to go beyond this. It purports
to define not how a vested interest is created, but to
define how it is maintained. As interpreted below,
Chapter 712 requires a vested owner to rerecord its in-
terest in the real estate. On th ?. basis of its having failed
to do so, the City's ownership was held extinguished by
a void deed executed in 1944.
Constructive notice is a legal fiction on which much
of the law of property is based. However, constructive
notice has no talismanic quality with relation to real es-
19
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1
tate. Eaeit''application should he scrutinized, to insure
notice "such as one desirous of actually informing . .
might reasonably adopt to accomplish it.'' Mullane,
supra. To hold t hat landowners have constructive
knowledge of a 196:3 legislative enactment requiring
them to take affirmative acts to maintain their
ownership of real estate might itself violate due process.
.11c('ord r. Smith, So.2d 70-1 (Fla. 1950).
But even if constructive notice of this Act were suf-
ficient, it is clearly not sufficient with regard to a wild
deed. 'I'o comport with due process, a property owner
would have to be fairly held on constructive notice both
of the Act and of' the wild deed.
Recording of a wild deed is not notice of a claim to
property; a wild deed is one executed by a stranger to
the record title "hung out in the air like 1-lahomet's cof-
tin. 1'oladian L. Johnson, 85 So.2d 140. 141 (Fla. 1956).
Recording of a wild deed is not even constructive notice
of anything. lived c. Fain. 1.15 So.2d 858 (Fla. 1962).
The 1944 conveyance was a wild deed in 19-14 . and
cannot be made valid by subsequent legislation. An act
cannot "breathe life into a corpse." Smith Brothers v.
Williams, 131 So. 3:15, 337 (Fla. 1930).
Therefore. by this Court's own repeated decisions,.
to apply Chapter 712 to validate wild deeds would divest
owners of existing interests in real property without
notice. Vet this was done below in clear violation of the
United States Constitution.
11111111111111111111111111
(h) Retroactive Application s The Act
Deprives A Vested Owner Of Property Without Due
Process of Law.
Retrospective application of Chapter 712 below has
destroyed vested property rights and constitutes a viola-
tion of due process. See, e.g.. Creary v. Creary's Estate,
338 So.2d 26 (1st Fla. DCA 1976); Biltmore Village, Inc.
v. Royal Biltmore Village, Inc., 71 So.2d 727 (Fla. 1954).
Yet the courts below have interpreted Chapter 712
as validating a void instrument recorded 19 years prior
to the legislative enactment.
The basic thrust of Chapter 712 is an attempt to -ef-
fect what may be a legitimate state interest: to lessen
the burden of title searches.
As interpreted below, however, Chapter 712
obliterates the vested rights of property owners and
awards them to persons whose interloping claims arise
from the past mistakes or calculated risks or even
deliberate omissions, made by a title searcher.''= By this
interpretation Chapter 712 not only retroactively alters
the duties of title searchers, it actually validates void in-
struments. Such a result is wholly inconsistent with due
process. And here it would divest the public of land
which by law the private claimants were bound to know
was sovereignty land.
'And the early dismissal with prejudice precluded any discovery on
this subject. It seems clear that St. Joe must have actually as well as con-
structively known of its illegal acquisition in 1944. Its failure to develop or
deal with this prime property for more than three decades supports this
conclusion.
21
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u
As indicated. statutes of limitations which preclude
a person from bringing suit after a reasonable time set
by the statutes may not be unconstitutional depriva-
tions of property, but a statute of limitations does not
begin to run unt il "there has been notice of the invasion
of a legal right or a person has been put on notice of his
right to a cause of action." Such statutes may be held
valid, therefore, because they give a person a reasonable
time after effective notice to seek adjudication of a claim
to property rights.
Even retroactive statutes of limitation may he valid
"where a reasonable time is allowed to prosecute an as-
serted right." Bach, r. Triplett, 32 So.2d 753. 755 (Fla.
1947). however, Chapter 712, as interpreted below, dif-
fers in effect from statutes of limitations in two signifi-
cant ways. First, it would divest not merely a cause of
action. but an existing. vested right in property. Sec-
ond. it Mould impose a new obligation or duty to
preserve a vested interest -- an owner would he required
to re-record his interest. As interpreted, therefore,
Chapter 712 is unconstitutional. for retrospective
legislation is invalid
"in those cases wherein vested rights are
adversely affected or destroyed or when a new
obligation or duty is created or imposed, or an
additional disability is established in connec-
tion with transactions or considerations
previously had or expiated."
McCord v.. Smith, 43 So.2d 704, 709 (Fla. 1950).
In this regard, it is important to note that Chapter
712 is not merely curative of technical or administrative
22
fohSILV
irregularities. It is not merely remedial ?`id therefore
perhaps protected by the rationale of such cases as
Board of ('nmm'rs of Everglades Drainage Dist. v.
Forhes Pioneer Boat Line, 86 So. 199 (Fla. 1920), rev'd
on other ;rounds, 258 U.S. :3:38 (1921) ). And unlike
Moyer C. ('lark, 72 So.2d 905 (Fla. 1954), where referring
to the general recording statute this Court stated that
"the statute obviously was not intended to have the
result of requiring a grantee to record his own deed
within a specified time or lose an otherwise valid title,"
it is not merely a recording statute.
Instead, the Act as applied divests vested (as op-
posed to contingent) property rights in a retroactive way
which Florida courts have repeatedly held violates due
process.
(c) As Interpreted By The Trial Court, The Act
Impairs The Obligations Of Contract.
United States Constitution.
Article I, Section 10, Clause 1, of the United States
Constitution provides in pertinent part: "No state shall
. . . pass any . . . law impairing the obligation of con-
tracts. . . ."
Chapter 712, as interpreted below, actually ex-
tinguishes vested property rig. -its, rights which are clear-
ly protected by the constituhional prohibition against
impairment of contract. A state may not be prohibited
from validly exercising the police power for the public
interest, and such laws as exist are implied into contrac-
tual obligations. Indiana ex rel. Anderson v. Brand, 303
U.S. 95, 58 S.Ct. 44:3, 82 L.Ed. 685 (1938). A state may
23
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not, hots „- r, retrospectively exercise the police power
to extinguish vested rights which in no way conflict in
and of themselves with the public interest.
'l'he State of Florida may well have a legitimate in-
terest in relieving the necessity for lengthy title
searches. and may have the authority to enact legisla-
tion which alters the methods and substance of creating
obligations. The State of Florida may not. however, ex-
tinguish otherwise Valid vested interests. if the Act is to
he interpreted. as the trial court and the Third District
have interpreted it, retroactively to extinguish a
property oNvner's vested interest in property, the Act im-
pairs contractual obligation in clear violation of Article
1. Section 10, Clause 1. of the United States Constitu-
tion. See 'Trustees of Dartmouth College v. Woodward,
17 U.S. 518..1 L.l:d. (329 (1819); Empire State Insurance
('i'mpany v. ('hafetz, 302 F.21 828 (5th Cir. 1962).
The Florida Constitution
The Florida Constitution, like the United States •
Constitution, provides that "no . . . law impairing the
obligation of contract shall be passed." Article I, Section
10. Florida courts have made clear that the State is not
prohibited by this provision from exercising the police
power in the public interest. See, e.g., Shavers V. Duval
('panty, 73 So.2d 684 (Fla. 1951); McConville v. Ft.
fierce Bank & Trust Co., 135 So. 392 (Fla. 1931).
However, as the Florida Supreme Court noted in
Yamaha Parts Distributors, Inc. v. Ehrrnan, 316 So.2d
557. 559 (Fla. 1975), "virtually no degree of contract im-
pairment has been tolerated in this state." It is clear
that the police power does not allow the State to ex-
tinguish vested rights which in no way conflict in and of -
24
themselves with the public interest. The Fyida case of
Biltmore Village, Inc. v. Royal Biltmort Village, 71
So.2d 727 (Fla. 19541, has become a leading case for the
rule that reversionary rights in property cannot be
destroyed by subsequent legislation. See 41. A.L.R.2d
1384.
Retroactive legislation is particularly suspect. In
Yamaha, this Court held that a statutory requirement
that a motor vehicle manufacturer give 90-days' notice
to a franchisee prior to cancellation of a franchise con-
tract did not apply retroactively.
"To justify retroactive application it is not
enough to show that this legislation is a valid
exercise of the state's police power because that
power, however broad in other contexts, here
collides with the constitutional ban on laws im-
pairing contracts." [at 559]
(d) The Decisions Below Constitute An Uncon-
stitutional "Taking" Of Property.
The Fifth Amendment of the United States Con-
stitution provides in pertinent part: ". . . nor shall
private property be taken for public use, without just
compensation."
This provision applies to the states by virtue of the
Fourteenth Amendment. See Chicago, B & Q Ry. Co. v.
Chicago, 166 U.S. 226, 17 S.Ct. 581, 41 L.Ed. 979 (1897).
When state action goes beyond mere regulation of
property rights and actually deprives an owner of title to
property, compensation is required.
25,
■
''is inconceivable that a state could con-
stitutionally authorize the taking or expropria-
tion of property without just compensation,
even if it did so after providing a hearing in all
of the other procedural rights which are embed-
ded in the concept of due process. Taking
property, whether by the United States, by a
state. a county, or by a municipality, requires
just con pensat ion."
Brault L. Town of Milton, 527 F.2d 730, 741-742 (2d Cir.
1975). See also, tiotomura v. County of Hawaii, 402
F.Supp. 95. 101 (1). Hawaii 1975); Cook C. Carlson, 364
F.Supp. 24, (D. S.D. 197 3).
Even following procedural safeguards, the state is
restricted to taking property for public use.
"The taking by a state of the private property
of one person or corporation, without the
owner's consent, for the private use of another,
is not due process of law, and is a violation of
the Fourteenth Article of Amendment to the
Constitution of the United States."
Mo. 1'ac. Hv. Co. v. Nebraska, 164 U.S. 403, 417, 17
S.Ct. 130, 1:35, 41 L.Ed. 489 (1896); Blankner v. City of
Chicago, 504 F.2d 1037, 1043 (7th Cir. 1974); Schneider
v. District of Columbia, 117 F.Supp. 705, 716-717 (D.
D.C. 195:3).
The decisions of the courts below have deprived the
('ity of its title to real estate and vested title in the
respondents, in violation of the Fourteenth Amendment
of the United States Constitution.
26
(e) Other Jurisdictions Hold : ii1ar Legisla-
tion Unconstitutional Or Construe It To Avoid The
Constitutional Problems Created Below.
Murrison v. Fenstermacher, 20:3 P.2d 160 (Kan.
1949), held unconstitutional a statute which provided
that deeds which had been of record more than 25 years
prior to the effective date of the statute were conclusive-
ly presumed to have conveyed perfect title,
notwithstanding any defect in the grantor's title. The
statute had a proviso that the presumption was not to be
applied in any action brought within one year from the
effective date of the statutory enactment. Noticing the
distinction between the disputed statute and curative or
limitation statutes. the court opined:
"The power of the Legislature to prescribe
within what reasonable time one having a mere
right of action shall proceed is unquestionable;
but there is a wide distinction between that
legislation which requires one having a mere
right to sue, to pursue the right speedily, and
that which creates the necessity for suit by con-
verting an estate in possession into a mere right
of action, and then limits the time in which the
suit may he brought. The mere designation of
such an act as an act of limitation does not
make it such, for it is in its nature more than
that." Dingey v. Paxton, 60 Miss 1038 . . . [at
1621
In Board of Education v. Miles, 207 NE 2d 181
(N.Y. 1965), a statute precluded all reverters created
prior to September 1, 19:31, unless recorded on or before
September 1, 1961. The court acknowledged that, unlike
27
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1
the ret.,rding acts, the statute was not designed "to
protect subsequent purchasers for value and without
notice. but for an object more akin to that of title
registration acts which are designed to perfect the
marketability of title." The court fount[ that recording
acts are a valid exercise of the police power to protect
subsequent purchasers, while the purpose of the instant
statute was merely to avoid lengthy title searches.
('iting Biltntnre L'illage. Inc. t. Royal Biltmore Village,
71 So.2d 727 ([•'la. 19541, the court concluded that under
the circumstances, the statute "cannot be sustained
. . . since it purports to bar the remedy before the right
to enforce it has matured." [at 1891
In State. Dept. of Highways v. Tucker, 170 So.2d
:371 (La. 19641. the Louisiana Supreme Court struck
down a statute that raised a conclusive presumption
that deeds to land abutting a right-of-way included the
seller's right-of-way unless the seller filed suit. or
recorded a notarial declaration.
"Such an alteration disrupts established land
tenure, transfers land from persons holding
clear titles, and defeats the reasonable expecta-
tions of landowners who have relied upon the
law in effect at the time of conveyance. As
retroactively applied, the statute impairs the
obligat ion of contracts and divests vested
rights. Consequently, it violates the federal and
state constitutions." [at 374, footnotes omit-
ted]
See also Cornish v. Kinder Canal Co., 267 So.2d
625, 6:31 (La. App. 1972).
28
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III
(f) Prior Florida Decisions Do Not support The
Constitutionality Of The Act.
The Third District assumed that Chapter 712 has
been upheld as constitutional by Marshall v. Hol-
lywood, Inc.. 236 So.2d 114 ( Fla. 1970). This Court in
that case in fact expressly reserved ruling on the issue of
constitutionality, because it was not "framed as an is-
sue" in the lower court;
"we join with the District Court in declining tor
consider such arguments because the con-
stitutionality of the Act was not framed as an
issue in petitioner's amended complaint, which
is the only complaint now before us. For pur-
poses of disposing with this litigation, we will
act on the assumption that the Act is con-
stitutional." [at 118, emphasis supplied]
To say that this is a determination of the con-
stitutionality of the Act is to ignore this Court's express
language.
The Third District also cited, as supporting the con-
stitutionality of Chapter 712, Campbell v. Horne, 3
So.2d 125 (Fla. 1941); Mahood v. Bessemer Properties,
Inc.. 18 So.2d 775 (Fla. 1944); Buck v. Triplett, 32 So.2d
75:3 (Fla. 1947); H.K.L. Realty Corporation v. Kirtley,
74 So.2d 876 (Fla. 1954); and In Re Brown's Estate, 117
So.2d 478 (Fla. 1960). Eacn of these cases involves
statutes of limitations, and is wholly inapposite.
Finally, it should be noted that the Act has been
construed to avoid conflict with constitutionally
protected property interests. See Reid v. Bradshaw, 302
29
ir
IIuIuuIIIiIII
8;o._'d I ' '1st Fla. 1)('A 197.1).
4. The Act Specifically Exempts An Agency Of
The Government, Such As The City Of
Miami, From Its Operation.
The question raised here is whether the City of
Miami as an agency of the State is exempted from the
Act with respect to this property. FSA 712.04 provides:
.. I"i'Ihis chapter shall not be deemed to af-
fect any right, title or interest of the United
States, Florida or any of it officers, hoards,
commissions or other agencies reserved in the
patent or deed by which the United States,
Florida or any of its agencies parted with title."
(emphasis supplied]
Miami is an agency of the State and, therefore, ex=
empt from t he ent ire chapter. See State v. City of
Auburndnli', 85 tio.2d 611 (Fla. 1956), where dealing
with tax proceeds distributions, this Court said:
"Within the orbit of the authority granted to it
by the state, a municipality is an instrumen-
tality or auxiliary agency of the state es-
tablished for the more convenient administra-
tion of local government. While it does not
share the state's sovereignty and enjoys only
such powers as are specifically granted, or
necessarily implied from powers specifically
granted, nevertheless, subject to these restric-
tions, a municipal corporation is in substantial
measure merely a projection of the state
30
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government to the local level." [at 613]'-•'
Similarly, see Loeb v. City of Jacksonville, 134 So. 205=
(Fla. 1931), in which this Court defined a city:
"A 'city' is a mere auxiliary to the state govern-
ment. It is a public institution for self-
government and "local administration of the
affairs of state. It is appointed and empowered
for that purpose and is therefore an agent of the
state for local administration of governmental
affairs." [ at 207, emphasis supplied]
Accord: Kaufman v. Tallahassee, 94 So. 697, 698 (Fla.
192:3); Turk v. Richard, 47 So.2d 543 (Fla. 1950); and
West v. Toren of Lake Placid, 120 So. 361, 366 (Fla.
1929); City of Miami v. Lewis, 104 So.2d 70, 72-3 (3d
Fla. DCA 1958). And cf. Florida Statutes 20.03(11)
(1974) defining "agency" as "an official, officer, com-
mission, authority, counsel, committee, department,
division, bureau, hoard, section, or other unit or entity
of government.'' [emphasis supplied]
The patents or deeds by which both the United
States and Florida parted with title reserved the right
and the interest of both the United States and the State
of Florida to have the use of the land restricted to public
use or more specifically, as to Florida, that species of
public use subsumed in the phrase "for municipal pur-
poses only." [ 7, 8]
When it conveyed the "submerged lands, including
waterfront and riparian rights" to Miami in 1919,
Florida delegated its duty as a trustee to Miami. For
purposes of application of § 712.04, therefore, Miami
31
i
stands ii► the place of the State, an agent with an in-
terest (fee simple title in trust ► reserved in the patentor
deed, and is. therefore, exempt from all of Chapter 712.
The legislative intent revealed by the broad limita-
tion of ;' 712.0.1 is clearly to preserve governmental in-
terest in land. This legislative intent is more emphatic
when Chapter 712 is compared to the Model Marketable
Record 'Titles Act," from which it derived. That Model
Act preserves only the "interests of the United States."
Florida's Legislature specifically wrote in the expansive
limitation of 712.04.
The analogy to adverse possession is compelling.
One cannot assert adverse possession against the
State '. the City'' or other governmental body."`. The
same should be true here. St. Joe should not be allowed
to perfect an interest in the 10.69 disputed acres against
the City, an agency of the State and a governmental
unit of the people of Florida, by mere passage of time.
Chapter 712's purpose is to simplify and facilitate
land title transactions by permitting good faith reliance
upon records which have existed not less than :30 years.
But a grant in derogation of sovereignty must be strictly
construed in favor of sovereignty. TIIF v. Claughton,
.uupro. at 786. Contrary to the position espoused by St.
Joe. the "strict requirements" of Chapter 712 are not
See Appendix.
'Pearce v. ('one. '.'. So.2d 360 (Fla. 1941) (title held by Trustees of the
interval Improvement Fund).
Waterman v. Smith, 94 So.2d 186 (Fla. 1957).
'55 ALR2d 554. See Esp. Patton v. Los Angeles, 206 CAL 662 (19293.
:32
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met by the mere passage of 30 years of a line of title. A
title searcher must not only in good faith examine the
records for a 30-year period. He must also ascertain that
the statute applies in the first instance — he must
review the conveyance out of the state.712.04. The
purpose of the Act was not to relieve the title searcher of
the burden of determining the validity of title. A good
faith title searcher is charged with notice of all statutes
affecting title, in this case with notice of the 1919 Act
and the fact that the foreshore of navigable waters was
held by the State in trust for the people of Florida.
Moreover, Chapter 712 does not in any way purport
to repeal the June 2, 1919, statute. Since it does not (and.
totally apart from the constitutional prohibitions which
would arise), the two statutes must be read if at all pos-
sible so as not to conflict with one another and so as to
give meaning and effect to each. Mann v. Goodyear T &
R Co., 300 So.2d 666 (Fla. 1974); Banana River Props. v.
City of Cocoa Beach, 287 So.2d 377 (4th Fla. DCA 1974);
Walton County v. BPI, 161 So.2d 45 (1st Fla. DCA
1964).
This property has been conveyed out of the State
only in a limited way, by conveyance to its agent, the
City of Miami. A good faith title searcher in 1944, fol-
lowing even the liberalized standards of the Act (had it
then existed), must have found that the land belonged
to the City as agent for the estate. Chapter 712 should
therefore be construed not to work a retroactive
forfeiture of the City's interest.
The Third District did so construe Chapter 712,
citing Odom v. Deltona Corp., 341 So.2d 977 (Fla. 1977).
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The "Phis% istrict ruled that interests reserved in the
State can be extinguished by the Act, notwithstanding
the Act's own language. Therefore, the City's interest
was extinguished whether or not it is an agency within
712.01's meaning. Such a holding is clearly not
sustainable on the basis of Odom. In Odom, the State
was challenging a deed over :3(1 years old from the
'1'ru-tees of the Internal Improvement Fund, deeds
which indisputably purported to convey certain lakes to
private persons. This Court held the State's arguments
precluded by the Act. What the Court had before it,
however. were "valid Federal and State grants of title to
real property without any reservation of public rights in
and to waters thereon." The Act, in fact, protects only
those rights "reserved in the patent or deed by which the
United States, Florida or any of its agencies parted with
title.- Such reserved rights were not presented in Odom.
Such reserved rights are clearly presented in the present
case. In (ldum the State itself had conveyed the lands to
private parties more than 30 years prior to bringing suit.
In the present case, title has never left the State to go to
any private party, but remains in the State's agent, the
City of Miami.
This Court in Odom further stated that
notwithstanding the Act, if the state had previously pur-
ported to convey to private persons submerged lands un-
der navigable waters. an action by the State to establish
its title to such lands would not be precluded by the Act.
"Appellants also argue for the application of
the 'notice of navigability' concept, i.e., that
the grantee of swamp and overflowed lands un-
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der a trustee deed takes with `notice' thi. a he
conveyance does not include sovereignty land.
In the case of a large lake, such as Lake
Okeechobee, a 500,000 acre lake,
we agree;
however, it seems absurd to apply this test to
small, nonmeandered lakes and ponds of less
than 140 acres and, in many cases, less than 50
acres in surface." [emphasis suppliedl
The opinion in Odom compels the conclusion that
the State's interest in lands beneath obviously
navigable waters, vested in its agent, the City of Miami,
cannot be extinguished by the Act. The Third District
ruled directly to the contrary.
5. It Was Error To Make A Factual Determina-
tion Of Estoppel In A Hearing Without
Evidence On A Motion To Dismiss.
Even a cursory reading of the transcript leaves the
unmistakable impression that the trial judge was
presuaded by his conclusion that the City's vested right
would ultimately he defeated by estoppel:
"If anybody has ever been estopped or waived
any rights —the City of Miami has been sitting
here with this land having been filled back in
the 20's. I would have to take judicial notice
that they have been getti-ig taxes on all of it all
this time." (R-208)
A trial court may not raise the issue of estoppel on
his own motion. Cox e. Holder, 345 So.2d 846 (1st Fla.
DCA 1977). St. floe should have been required both to
plead and prove such affirmative defenses, and the City
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;houl(I hay _ 'teen allowed to plead and prove any affir-
mative defenses to St. Joe's claim of estoppel.' The trial
judge's actions directly violated the rules of procedure.
See r.g.. ('raft c. Young, 1SS So.2d 859. 8(10 (1st Fla.
1)('A 1966): 1.. C..11+trris. Inc. t'. Allison, 277 So.2d 28
(:Id Fla. 1)('A 197:3), appeal after remand.:309 So.2d 9
(:3d Fla. 1)('A 1975).
Furthermore, if defendants had plead estoppel and
waiver. that would have served only to raise a factual is-
sue. A hare allegation of estoppel is not a legally suf-
ficient ground for dismissal. See Thiesen v. Gulf F & A
By. Co., 78 So. 491 (Fla. 1917); Brickell tv. Trammell, 82
So..221 (Fla. 1919); Wernle tv. Bellemead Development
Corp., :M8 tio.2d 97 (Fla. 1975).
Although this case was not allowed to proceed to
discovery. the deeds alone support the conclusion that
as a matter of law the City would not he estopped from
asserting this claim.
'1'„ the extent that the trial court held the City estopped, it denied the
City its right to a trial on this and other important issues. Counsel for the
('its. at the hearing in the trial court on the motion to dismiss, objected
that tit the trial court were going to hold that the respondents had title by
virtue of the Butler Act. factual allegations could and would be made show-
ing that FE("s putative dredge and fill rights were only to fill nut to the
channel. At the time in question, the channel was located at the approx-
imate present location of Biscayne Boulevard, thereby making all of the
property east and .south of Biscayne Boulevard illegally tilled and not a
proper basis for any claim of title by any of St. doe's predecessors in
putative interest.
The trial judge refused to accept such an amendment. saying that
..Quid he something "for the appellate court to consider." Such a refusal to
ails'% amendments is improper. The pleadings also allege that the 4.24 acre
yacht basin in question was not filled until 1949. No title transaction took
place after the tilling and, therefore, the 30-year period has not yet com-
menced to run. Even if the 30-year statutory period commenced after the
filling was completed, the statutory period would not expire until 1979.
:16
"While the doctrine of estoppel can Ix );plied
against the state or its subdivisions (Trustees
of Internal Improvement Fund v. Claughton,
Fla.1956, 86 So.2d 775), the instances are rare
when the doctrine will he so applied. It will be
invoked only under very exceptional circum-
stances, which trust include some positive act
on the part of an authorized official, and in no
instance does it appear that the do
ctr ne of
equitable estoppel has been appliedto divest
the state of its land. Bryant v. Peppe,
238 So.2d 836. See also Adams v. Crews,
Fla.App.1958, 105 So.2d 584."
Jefferson National BankDC197)
v.at Sunny Metro
Dade
County, 271 So.2d 201 214
(3d Fla.
Estoppel requires a reasonable reliance directly
upon the misleading acts or negligence of the party
against whom this estoppel is being asserted, all to the
asserting party's injury.
Here, there was no reasonable reliance on St. Joe's
part, only hope (or calculated risk). St. Joe was on
notice of the City's title
nndo nly butder the because`thelce of
1919
navigability" doctrine of
grant of submerged lands to the City was a matter of
great consequence, especially to commercial landowners
around Biscayne Bay. Certainly, there was no mis-
leading act or negligence which could steal thisland from the
e in its
unreasonable hope that it
City.
Though, as noted above,atare cases in which
trialcompelled the
the particular facts developed t
37
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1
conclusion that estoppel should lie against a governmen-
tal agency,' it has long been the law that where the con-
dition of the title is equally available to all estoppel will
not lie.'
St. Joe has never disputed that it had knowledge of
the City's title. Any acts on its part were made not in
reliance but in hope.
"Moreover, one's own wrongful act ordinarily
cannot serve as a basis of a claimof estoppe
as an eel
against another, and it can be app s
toppel against estoppel. Florida Land Inv. Co.
v. Williams, 98 Fla. 1258, 116 So. 642."
Jefferson National Bank at Sunny Isles t'. Metro Dade
Count\•, supra, at 214.
Finally, before there can be an estoppel there must
be an injury to the asserting party. Clearly, St. Joe has
not been injured by the rents which it hahb e n c greatly
over the years. On the contrary,
it benefited. St. Joe has no investment in this land which
it has not long ago recovered.
'Odom v. The Deltona Corp., supra; TIIF v. Claughton. supra::
"Price v. Stratton, 33 So. 644 (Fla. 1903); see also Martin v. Busch, 112
So. 274 (Fla. 1927); and Odom, supra, page 988 at note 9.
:38
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CONCLUSION
The courts below have construed an act so as to
validate a demonstrably void deed which was illegally
placed of record nearly two decades before the passage of
the Act. They have ignored Florida case law which has
uniformly accorded no validity or even notice -ability to
wild deeds.
By so doing, the courts below have imposed upon
the Act an unconstitutionality so pervasive that it runs
afoul of almost every constitutional protection accorded
vested property rights.
Moreover, the courts below have disregarded the
expressed, specific legislative
intent not even as here, the con -
have the
veyance chapter apply at all —where,
veyance out of the state not only is directly (and ex-
clusively) to a state agency, but a specific, public use
restriction is expressed in the conveyance.
Finally, in order to achieve this completely er-
roneous and unconstitutional construction, the courts
below have looked the other way and ignored the most
egregious procedural violations. Pleaded exceptions to
the Act, though unchallenged and unstricken, are
treated as non-existent. And the trial judge's engaging
in a one -eyed fact-finding role at a hearing on a motion
to dismiss is approved: "it doesn't matter."
But it does matter. Sovereignty land has been
usurped by private parties. Those private parties
knew —or must be charged with knowing —that they
were taking sovereignty
really
against the City (and there is
theory of estoppelnot),
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they would be estopped to assert it.
The opinion below should he quashed. The statute
should he construed so as to comport with constitutional
standards. And, in any event, it should he enforced only
according to its own terms. It cannot therefore he ap-
plied to the City.
Respectfully submitted.
LAW OFFICES
GUY B. BAILEY. .JR.
Attorneys for Petitioner
1820 One Biscayne Tower
Miami, Florida 33131
By
Guy B. Bailey, .Jr.
CERTIFICATE OF SERVIC
I HEREBY CERTIFY that a true copy of the
foregoing Petitioner's Brief on the Merits was mailed to
Shutts & Bowen, 1000 Southeast First National Bank
Building, Miami, Florida :3:3131; Sibley, Giblin,
Levenson & Ward, 1301 Dade Boulevard, Miami Beach,
Florida :3:31:39; Steel Hector & Davis, 1400 Southeast
First National Bank Building, Miami, Florida 33131;
and Russo, Van Doren & Allen, P.A., 4685 Ponce de
Leon Boulevard, Coral Gables, Florida 33147; this 7th
day of July, 1977.
Of CoanseE