HomeMy WebLinkAboutSubmittal-Opinion Of CounselLAW OFFICES
SERBER & WEALCATCH, P.A.
Hand -Delivery
Jorge Fernandez, City Attorney
City of Miami
444 S.W. Second Avenue
Miami, Florida 33130
TURNBERRY PLAZA, SUITE 801
2875 NORTHEAST 191"STREET
*VENTURA, FLORIDA 33180
TELEPHONE (305) 932-6262
TELECOPY (305) 933-9393
October 28, 2004
OPINION OF COUNSEL
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,,Re: 02, L.L.C. submission for MUSP approval; Bankers Park Subdivision
Our File No.: 132-63
Dear Mr. Fernandez:
I represent 02, L.L.C, a Florida limited liability company, which is the developer for a
Major Use Special Permit for a 117 unit residential project located on the west side of North
Bayshore Drive and NE 28th Street. I am a member of the Florida Bar since 1994 and a member
of the District of Columbia Bar since 1995. For approximately the last ten years I have been
practicing and specializing in real estate transaction law. I am an agent of First American Title
Insurance Company and an agent of Attorney's Title Insurance Fund (The Fund). This firm was
retained by 02, L.L.C. for the acquisition of Lots 1, 2, 3, 4, 49 and 50 located in the Banker's
Park Subdivision and more specifically abutting NE 28th Street.
The developer has proffered to landscape and maintain the area which is approximately
190 feet in length by 28 feet in width (5,320 square feet) (the "Land Strip"), which is located
directly adjacent to Biscayne Bay. A copy of the tax printout is enclosed with the Land Strip
identified by the red outline (Exhibit "1").
This letter addresses the ownership of the Land Strip by the City, and not being owned by
the property owners of the Bankers Park Subdivision. The tax printout which includes the folio
number for the Land Strip which is 01-3230-017-0420, identifies the City of Miami as the
property owner, although the City's Asset Management Department has stated that they have no
record of the City owning this land.
/
SUBMITTED INTO THE
PUBLIC RECORD FOR
ITEM Fz., ON io-as o4
The purpose for this request is because the developer has a Major Use Special Permit
scheduled for City Commission on October 28, 2004, which includes in its gross lot area an
extension of 70 feet into Biscayne Bay, as permitted in the City's Zoning Ordinance. The
developer's MUSP also includes providing landscaping and maintaining this Land Strip in order
to beautify the neighborhood. The developer has been meeting with the surrounding property
owners to obtain their input on the proposed landscape for this area. Historically, this has been a
piece of land that has existed with no maintenance or upkeep and had been plagued by Australian
Pines, which are an invasive non native species which have been proven to be a hazard during
hurricane season. Photographs are enclosed (Exhibit "2"). The Land Strip would continue to
remain open to the public.
However, there is a property owner in the neighborhood who is taking the position that
the Land Strip is owned by all the property owners of the Bankers Park Plat recorded in Plat
Book 2 at Page 53 (Exhibit "3"). We believe this position erroneous. The Plat states:
KNOWN ALL MEN BY THESE PRESENTS — That we W.S.
Witham and wife Jean Witham hereby file the foregoing plat, the
same being known as Bankers Park and being a subdivision of the
land described as follows — Beginning on the range line between
Ranges Forty-one (41) and Forty-two (42) at the southwest comer of
the fractional northwest quarter of Section Thirty (30), Township
Fifty-three (53), South of Range Forty-one (41) East; thence run north
along said Range line ten (10) rods; thence run east eighty (80) rods
more or less to low water mark on Biscayne Bay, thence run south on
said low water mark ten (10) rods more or less to the South east
corner of said fractional northwest quarter, thence run west eighty
(80) rods more or less to point of beginning.
Also block fifteen (15) of Broadmoor and addition to the City of
Miami, Fla; said block fifteen (15) being a strip of land sixty (60) feet
north and south; 1,365 feet more or less and running from what is
known as Biscayne Drive to the waters of Biscayne Bay together with
all riparian rights and water privileges.
The Plat also states "Witham Ave is dedicated to owners of lots abutting on same, and
each lot owner is guaranteed the right to use the Bay Front" [Emphasis Added]. The Plat then
"Notes" the following: "All Lots to have Bay Front Rights" [Emphasis Added]."
It is our opinion that said statements define the area included within the Plat and grant the
subdivision property owners the dedication of Witham Avenue (n/k/a N.E. 28th Street) and the
right for access and use; but the Plat does not confer ownership of the Land Strip to the
subdivision owners.
With regard to the issue of ownership of the Land Strip, we have hired First American
Title Insurance Company, which has conducted a title search on the Land Strip, going back to
Submitted Into the public
record in connection with
2 item Pz--r on to -•>-2 -o 't
Priscilla A. Thompson
City Clerk
1913 (the year the Plat was filed for record), and the only deed that has been found is from 1926
which grants riparian rights of the Land Strip to the City of Miami (Exhibit "4").
Further research has been conducted and upon review of the Plat and the City's
Municipal Atlas Sheet 21-AF (Exhibit "5"), it is evident that the Land Strip was originally water
within Biscayne Bay but at some point after was filled as shown on the aerial photographs dated
1945 and 1957 (Exhibits 6 and 7).
One of the many reasons why we believe that the subject Land Strip is in fact owned by
the City is because the Land Strip is governed by the Butler Act enacted by the Florida
Legislature in 1921. This legislation provides that ownership of all filled in submerged lands
vest in the upland owner. North Bayshore Drive is a public City street and is directly adjacent
and upland to the Land Strip.
The Florida Supreme Court explained the operation of the Butler Act in City of West
Palm Beach v. Board of Trustees of the Internal Improvement Fund, 746 So. 2d 1085 (Fla. 1999)
(Exhibit 8). As explained by the Court in the City of West Palm Beach decision, all of Florida's
submerged lands, "including the shore or space located between the high and low water marks,"
became vested in the State of Florida when Florida became a State in 1845, as codified in the
Riparian Rights Act of 1856. City of West Palm Beach, 746 So. 2d at 1088-89. According to the
Court, the 1921 Butler Act re-enacted the Riparian Rights Act of 1856 and worked to vest in
upland`property owners fee simple title "to submerged lands upon which upland owners
constructed certain improvements in the interest of encouraging commerce by developing
waterfront property." City of West Palm Beach, 746 So. 2d at 1086.
The Court also recites the text of the Butler Act in its reported decision, as follows:
Section 1. Whereas, It is for the benefit of the State of Florida that water front
property be improved and developed; and
Whereas, the State being the proprietor of all submerged lands and water
privileges within its boundaries, which prevents the riparian owners from
improving their water lots; therefore
The State of Florida, for the consideration above mentioned, subject to any
inalienable trust under which the State holds said lands, divests itself of all right,
title and interest to all lands covered by water lying in front of any tract of land
owned by the United States or by any person, natural or artificial, or by any
municipality, county or governmental corporation under the laws of Florida, lying
upon any navigable stream or bay of the sea or harbor, as far as to the edge of the
channel, and hereby vests the full title to the same, subject to said trust in and to
the riparian proprietors, giving them the full right and privilege to build wharves
The West Palm Beach Court also explained that the Butler
legislation in 1951, except as to Miami -Dade and Palm Beach
the Butler Act except as to Dade and Palm Beach Counties.
253.129, Fla. Stat. (1997))." City of West Palm Beach, 746 So
3
. 2d at 1086 n.3.
Act was repealed in favor of replacement
Counties: "In 1951, the legislature repealed
Ch. 51-26776, Laws of Fla. (codified at §
Submitted Into the public
record in connection wi,th
item P2--7 on to)`� aL(
Priscilla A. Thompson
City Clerk
into streams or waters of the bay or harbor as far as may be necessary to affect the
purposes described, and to fill up from the shore, bank or beach as far as may be
desired, not obstructing the channel, but leaving full space for the requirements of
commerce, and upon lands so filled in to erect warehouses, dwellings or other
buildings and also the right to prevent encroachments of any other person upon all
such submerged land in the direction of their lines continued to the channel by bill
in chancery or at law, and to have and maintain action of trespass in any court of
competent jurisdiction in the State, for any interference with such property, also
confirming to the riparian proprietors all improvements which may have
heretofore been made upon submerged lands.
Provided, that the grant herein made shall apply to and affect only those
submerged lands which have been, or may be hereafter, actually bulk -headed or
filled in or permanently improved continuously from high water mark in the
direction of the channel, or as near in the direction of the channel as practicable to
equitably distribute the submerged lands, and shall in no wise affect such
submerged lands until actually filled in or permanently improved.
City of West Palm Beach, 746 So. 2d at 1088 (quoting, Ch. 8537, Laws of Fla. (1921)) (emphasis
added). Applying the foregoing language of the Butler Act, the Court in City of West Palm
Beach case held that the property in question did not vest in the City of West Palm Beach
because the property was dredged but was never "bulk -headed" or "filled in or permanently
improved." In short, the Court held that dredging alone is not a "permanent improvement" under
the Act. But in this case, there is no doubt that the Land Strip was in fact filled in and "bulk -
headed" with a concrete seawall.
Because the Land Strip was filled along with the construction of a seawall and it being
upland to North Bayshore Drive, ownership and title is vested in the City under the clear
mandate and provisions of the Butler Act.
Encls.
cc: 02, L.L.C.
4
Very truly yours,
Daniel J. Serber
Submitted Into the public
record in connection with
item
on to a
Priscil{a A. Thompson
City Clerk