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Allen v. McMillion

Citations: 82 Cal. App. 3d 211; 147 Cal. Rptr. 77; 82 Cal. App. 2d 211; 1978 Cal. App. LEXIS 1667Docket: Civ. 50651

Court: California Court of Appeal; June 28, 1978; California; State Appellate Court

Narrative Opinion Summary

This case involves a boundary dispute between neighboring property owners concerning a chain link fence believed by the plaintiffs to mark their property line, while a survey showed it was inside the defendants' property. The plaintiffs brought claims including quiet title, adverse possession, and trespass, among others, after the defendants removed the fence. The trial court granted summary judgment in favor of the defendants on all claims except trespass, which the plaintiffs appealed. The Court of Appeals affirmed the trial court's decision, agreeing that there was no material issue of fact regarding the agreed boundary doctrine due to evidence showing no uncertainty or agreement on the boundary. However, the court reversed the dismissal of the trespass claim, underscoring that peaceable possession allows for a tort claim against forcible entry, aligning with state policy against self-help in property disputes. The case emphasizes the protection of possessory interests against forcible actions, reflecting broader legal principles that discourage self-help measures and prioritize legal processes for resolving property disputes.

Legal Issues Addressed

Agreed Boundary Doctrine

Application: The court found that the agreed boundary doctrine did not apply because there was no mutual agreement or uncertainty about the true boundary between the properties.

Reasoning: The trial court deemed Lipstone's declaration significantly undermined the appellants' argument for an agreed boundary, as it was uncontradicted and established that there was no uncertainty or agreement about the true boundary.

Forcible Entry and Tort Claims

Application: The court emphasized that forcible entry, even without personal injury or property damage, can support a tort claim due to legislative policy against self-help measures.

Reasoning: A cause of action in tort exists for personal injuries or property damage resulting from forcible entry, regardless of the defendant's ownership or entitlement to possession, according to English courts.

Summary Judgment Standards

Application: The court concluded that summary judgment was appropriate for all claims except trespass due to lack of evidence showing material issues of fact on the agreed boundary doctrine.

Reasoning: The Court of Appeals focused on whether material issues of fact existed regarding the claims based on the agreed boundary doctrine. The court confirmed that summary judgment was correctly granted for all causes of action except trespass.

Trespass and Peaceable Possession

Application: The court allowed the trespass claim to proceed because the Allens were in peaceable possession and the McMillions' entry was considered forcible.

Reasoning: Consequently, in the current case, the Allens' peaceful possession was undisputed, and the McMillions' entry was forcible, necessitating the reversal of the dismissal regarding the trespass claim.