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Ridgefield Land Co. v. Detroit
Michigan Supreme Court
241 Mich. 468, 217 N.W. 58 (1928)
Ridgefield Land Co. (Ridgefield) (plaintiff) submitted a proposal to the city of Detroit (the city) (defendant) for a plat containing 80 acres of land between Pembroke Avenue (Pembroke) and Livernois Avenue (Livernois). The general plan adopted by the city imposed requirements on the width of streets. Under the authority conveyed by Michigan state law, the city provided in its charter for the appointment of a city plan commission of nine members with the authority to approve plats of land within the city. The streets of the city were originally designed for horse and buggy travel, so they were too narrow for modern traffic conditions, and it was necessary to widen existing streets and prevent the establishment of more narrow streets for convenience and safety. The city plan commission developed a general street plan for the width of streets in the city. Under the general street plan, the city plan commission had the power to refuse to record any plat that did not conform to the requirements. Based on the master plan, Pembroke was required to be 120 feet in width and Livernois 86 feet. Ridgefield’s proposed plat provided for a width of 66 feet for both Pembroke and Livernois. After several submissions, Ridgefield’s application was conditionally approved, provided that Ridgefield establish a 10-foot building line on Pembroke and dedicate an additional 17 feet for Livernois. Ridgefield refused to accept the proposed conditions and brought an action in the circuit court to compel the approval of the plat as Ridgefield had proposed. Ridgefield argued that the city had no authority to require a greater width as a condition for the approval of a plat and that such a requirement was an infringement on Ridgefield’s constitutional rights because it compelled the dedication of private property for public use without compensation. The circuit judge held that state law and the city charter conferred power on the city to adopt a general street plan and to refuse to approve and record plats that did not conform to the plan. Ridgefield appealed.
Rule of Law
Holding and Reasoning (McDonald, J.)
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