The City of Oak Hill appealed a trial court ruling that determined 'parcel 109' was outside its municipal boundaries, thus not subject to the city's exclusively residential zoning restrictions. The dispute arose when AAMP, LLC began construction on the parcel without the necessary permits. The City of Oak Hill sought a temporary restraining order and a permanent injunction against AAMP for violating municipal ordinances. The trial court issued a temporary restraining order on March 14, 2000, prohibiting further construction.
During the proceedings, the City presented affidavits asserting the parcel was within its boundaries, while AAMP provided contradictory evidence claiming it was within the Metropolitan Government of Nashville and Davidson County's jurisdiction. After a full hearing, the court found the parcel was indeed outside Oak Hill's jurisdiction, relying on the testimony of experts who supported this conclusion. The City argued the trial court misinterpreted the petition for incorporation regarding the boundaries, contending it should include the center line of Franklin Pike. The Court of Appeals affirmed the trial court's decision.
The court evaluated the intent of the petition by examining various circumstances, including maps and expert testimonies. Key findings include:
1. The primary issue is whether Parcel 109 is under the jurisdiction of the City of Oak Hill or the Metropolitan Government of Nashville.
2. Parcel 109 was owned by the Interurban Railroad in 1928, which quitclaimed the right of way to the Tennessee Department of Transportation in 1929. However, this deed was not recorded until 1977, during which the State used parts of the property to widen Franklin Pike.
3. The City of Oak Hill, chartered in 1952, adopted zoning regulations to maintain a residential character, which specifically excluded a triangular notch along Franklin Pike from its city limits.
4. Oak Hill also recorded a major street plan that reflected this exclusion.
5. Following the consolidation of Nashville and Davidson County's governments on April 1, 1963, Oak Hill continued as an independently governed satellite city within Nashville's boundaries.
6. By 1960, the Interurban Railroad was defunct, and the Metropolitan Tax Assessor assigned ownership of the land to adjacent property owners, some of whom were aware of this change while others were not.
7. On December 6, 1996, the Metro Zoning Administrator confirmed that Parcel 109 was zoned for commercial use and fell within the Metropolitan Government's jurisdiction, referencing a 1944 planning map that indicated the area was part of the State right of way.
8. The case hinges on whether Parcel 109 is correctly classified within Oak Hill's limits or those of the Metropolitan Government, as evidenced by conflicting maps.
9. The consolidation of Nashville and Davidson County's functions created the Metropolitan Government, as authorized by the Tennessee Constitution and relevant statutes.
These points summarize the court's findings and the central legal issues regarding the jurisdiction of Parcel 109.
Metro Code, Section 1.02 establishes that the Metropolitan Government encompasses all of Davidson County as of April 1, 1963. According to Section 18.15 of the Metropolitan Charter, cities in Davidson County not dissolved by the Charter retain their existence but cannot annex areas from the Metropolitan Government, preventing Oak Hill from extending its boundaries. Tennessee Code Annotated 7-1-106 discusses excluded smaller cities, while Section 18.15 aligns with this provision. Tennessee Code Annotated 6-51-302 permits municipalities to adjust boundaries through mutual contracts to clarify contiguous areas.
At its incorporation in 1952, the City of Oak Hill recorded maps indicating that Parcel 109 was outside its limits and was owned by the Tennessee Department of Transportation from 1929 to 1979. The State acquired Parcel 109 for right of way purposes, and it remained under state ownership until it was quitclaimed to Mr. Summar in 1978. The Court prioritized the testimony of Freddie Stroupe and Lon West from the Metropolitan Government over other witnesses regarding the maps' significance.
The Court established that Oak Hill could not acquire Parcel 109 through a new zoning map in 1988 or by approving a subdivision plat that incorrectly included it, as no agreement with Metro was in place. The Court's findings are presumed correct, with no evidence contradicting them. The appellant raised four issues regarding the trial court's findings, arguing that the court erred in concluding that Parcel 109 was outside Oak Hill's boundary, in holding that Oak Hill could not include state-owned property, in the application of Tennessee Code Annotated section 6-51-302, and in the determination that Oak Hill could not extend its boundaries.
Oak Hill's petition for incorporation outlines the specific boundaries of the proposed City of Oak Hill, starting from the intersection of Thompson Lane and Franklin Pike and detailing a series of directional points and margins along various roads and railway right-of-ways. The trial court analyzed the petition, noting that "margin" was used synonymously with "right-of-way," which raised questions about the easterly boundary's location. Legal principles dictate that boundary determinations are primarily a legal matter for the court, while factual determinations are made by the trier of fact. The Supreme Court emphasized that courts ascertain existing corporate limits and verify compliance with legal standards, without stepping into the legislative domain of municipal bodies.
On appeal, Oak Hill's primary argument focuses on the existence and description of its boundaries. Legal precedent suggests that when a deed specifies a boundary along a street, the intent of the grantor regarding the fee in the street will guide interpretation; absent clear intent, the grantee is presumed to own to the street's center. The appellant advocates for applying the center line doctrine to extend Oak Hill’s boundaries into Franklin Pike. The court notes that in legal review, no presumption of correctness applies to the trial findings. The center line presumption necessitates that the deed explicitly describes boundaries adjacent to a street and that the grantor holds title to the street in question.
The Court identified ambiguities in the petition regarding the term "margin," a specific monument referenced, and the eastern boundary of Oak Hill. It concluded that the incorporators did not intend to include the center line of Franklin Pike within the city’s boundaries. Evidence from contemporaneous maps indicated that parcel 109 was excluded from Oak Hill's boundaries at the time of incorporation, as it was owned by the state highway department. The Court noted that expert testimony on the term "margin" and evidence concerning the right-of-way for Franklin Road did not contradict the trial court's findings. The appellant argued that state right-of-way could be included in city boundaries, but the Court maintained that the intent of the incorporators was paramount; since they did not intend to include parcel 109, the question of inclusion was unnecessary for the ruling. The Court asserted that any later attempts to include parcel 109 in city maps violated the Metropolitan Charter's prohibition on boundary expansion. Consequently, the 1988 zoning and street maps that included parcel 109 were deemed ineffective. The trial court's determination that parcel 109 lies outside Oak Hill's limits and is not subject to its zoning restrictions was affirmed, and the case was remanded for further proceedings.
