Matter of Ossining Urban Renewal Agency v. Lord, 60 N.Y.2d 845 (1983)
A stipulation between parties regarding the facts of a case, especially concerning property rights like easements, is binding and conclusive, influencing the valuation of those rights even if certain aspects are undefined.
Summary
This case addresses the enforceability of a stipulation regarding an easement’s scope and its impact on valuation during a condemnation proceeding. The Ossining Urban Renewal Agency (OURA) condemned an easement owned by Pine Top. A prior stipulation conceded the easement provided Pine Top’s only access to a public road, including passage over state land. The Court of Appeals held that OURA was bound by its stipulation and that the easement’s valuation should reflect this access, even if the exact route across state land was undetermined. This highlights the importance of stipulations in defining the scope of property rights in legal proceedings.
Facts
Elissa Lord conveyed a 13.68-acre parcel to Pine Top, granting an easement for ingress and egress. This easement was stipulated to be Pine Top’s only access to a public road. The easement purported to cross Lord’s remaining 5.5-acre parcel and state-owned land to reach Snowden Avenue. The Ossining Urban Renewal Agency (OURA) condemned the easement. Previous litigation established that the easement over Lord’s land was extinguished. The commissioners of appraisal valued the easement as providing no access to a public road due to the uncertain nature of access over state land. The renewal agency stipulated that the easement granted Pine Top was inclusive of passage over State land and the litigation proceeded on that assumption.
Procedural History
The Supreme Court initially ruled on the matter. That order was reinstated by the Court of Appeals in a prior decision: Matter of Ossining Urban Renewal Agency v Lord, 39 NY2d 628. The case was then remitted to the Supreme Court to remand to the commissioners of appraisal for further proceedings to properly value the easement. The Appellate Division’s order was reversed by the Court of Appeals, who then remitted the matter to the Supreme Court.
Issue(s)
Whether the Ossining Urban Renewal Agency was bound by its stipulation that the condemned easement provided Pine Top with access to a public road, even if the easement included passage over state land and the exact location of access was undefined.
Holding
Yes, because the CPLR 3222 submission constituted a stipulation between the parties of the facts stated in the submission and was conclusive of such facts as between the parties to the proceeding. Having stipulated that the easement granted Pine Top was inclusive of passage over State land, the renewal agency was bound by its concession.
Court’s Reasoning
The Court of Appeals emphasized that stipulations are binding agreements regarding the facts of a case. The court cited Mann v Simpson & Co., 286 NY 450, noting the stipulation was conclusive of such facts as between the parties to the proceeding. By stipulating that the easement provided Pine Top’s only access to a public road, including passage over state land, OURA was bound by that concession. The court stated, “Having stipulated that the easement granted Pine Top was inclusive of passage over State land and the litigation having proceeded on that assumption and having reserved no issue concerning the effect of so much of the easement as purported to authorize Pine Top to cross State land, the renewal agency was bound by its concession that the easement gave Pine Top access to a public road.” The court also cited Campbell v State of New York, 32 NY2d 952. The fact that the exact location of access over state land was undetermined was irrelevant because the stipulation conceded that the right existed. The possibility of the State later providing access did not negate the existing stipulated right. The court concluded it was error for the commissioners of appraisal to evaluate the condemned easement on the basis that it provided no right of passage over the State’s land. Whatever the nature of Pine Top’s right to cross the State’s land, the stipulation conceded that it had such a right. It was, therefore, entitled to damages calculated on the basis of that right.