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Housing Authority of Camden v. Reeves
Citations: 244 Ark. 783; 427 S.W.2d 196; 1968 Ark. LEXIS 1419Docket: 5-4557
Court: Supreme Court of Arkansas; May 6, 1968; Arkansas; State Supreme Court
The Camden Housing Authority initiated condemnation proceedings to acquire 6.236 acres from a 73-acre tract owned by the Reeves family, with a jury valuing the property at $38,000. The Authority challenged the court's decision to permit the introduction of an unrecorded plat that depicted the entire tract as a residential subdivision with public streets and lots. Previous cases have shown inconsistencies regarding the admissibility of such plats, particularly when the subdivisions they represent are not fully developed. The court has historically excluded these types of plats to prevent misleading juries about property value, as they may not account for essential development costs like infrastructure. Notably, cases have emphasized that plats should not be admitted if the subdivision exists only on paper, as discussed in relevant rulings. However, unrecorded plats may be admissible if the subdivision has some realistic basis, as seen in a case where the land was near developed areas and its best use was residential. In the present case, the Housing Authority did not request a cautionary instruction for the jury concerning the plat's use, which could have mitigated potential misconceptions about market value. Evidence regarding the property's highest and best use for residential purposes and existing improvements had been admitted for limited purposes, minimizing the risk of jury speculation that could prejudice the Authority. Appellant claims that the exhibits in question are inadmissible based on a precedent set in Arkansas State Highway Comm. v. Watkins. However, the circumstances differ significantly, as testimony in Watkins included specific values per lot, which is absent in the current case. Instead, the witnesses provided valuation on a raw acreage basis. The court found that the admission of appellees’ Exhibits A and B was appropriate given the case details. The 73-acre tract has been owned by the Reeveses for over fifty years, during which Bob Reeves surveyed the land, created lots, and constructed homes. The Reeveses had also developed infrastructure, including paved streets and utility lines, prior to the Housing Authority's action, with approximately one-third of the property accessible to these improvements. The plat introduced showed the existing developments and the proposed division into lots, reflecting significant progress beyond mere planning. The Housing Authority argued that the plat's inclusion was unnecessary; however, the court determined that the development's status justified its admission. The court concluded that the exhibit aided in understanding the testimony and that any concerns could have been addressed during cross-examination or with cautionary instructions. Ultimately, the court affirmed the decision to admit the exhibits.