Security Land & Exploration Co. v. Burns

Background

A private landowner who bought from the original government patentees claimed a strip of land between a meander line shown on the official survey plat and the actual shore of Cedar Island Lake. The plat showed a meander line much closer to the lots than the real lake, but the surveyor never ran the interior lines, and the plat was found to be fraudulent. The patents described specific acres and set out courses and distances that gave the patentees about 140.87 acres, while using the plat’s meander line to reach the real lake would have given roughly 571 acres and required crossing more than 1,000 acres of upland.

Reasoning

The Court considered whether the picture of the lake on the plat should control over the written courses and distances. It explained that natural landmarks can control measurements only when they reasonably match the facts and the parties’ intent. Where the official plat is grossly incorrect or fraudulent, the lake shown on the plat does not become a true boundary. Because the patentees had received and were in possession of the acreage stated in the patents, and because the plat was wildly inaccurate, the Court refused to let the landowner extend boundaries out to the distant shoreline.

Real world impact

The decision keeps land titles tied to the acreage and survey distances stated in patents when a plat is grossly wrong or fraudulent. Landowners cannot press large new waterfront claims based on a mistaken meander line, and the government is not forced to convey more land than was described and paid for.