## Facts

- A public road known as the New Hope‑Whitaker Springs Road existed in West Feliciana Parish, Louisiana.
- Between 1932 and 1935, the road was reworked and renamed Morris Road.
- The new Morris Road generally followed the old roadbed, but in a small section it was laid slightly to the west of the old roadbed, leaving the two routes separated but roughly parallel.
- In 1941, heirs of Green D. Spillman partitioned a tract of land into five lots using the “public road” as a boundary reference in the partition document; an attached sketch depicted the boundary as a single straight road labeled “public road.”
- In the area where Morris Road had shifted west, Lot One lay to the west of the road boundary and Lot Two lay to the east, making the location of the “public road” boundary significant.
- Lot One’s description in the partition treated the tract as bounded “on the East by the Public Road.”
- In 1955, an heir conveyed Lot One, and the deed described the eastern boundary as the “public road (New Hope‑Whitaker).” Subsequent conveyances of Lot One repeated this reference.
- Charles E. Griffin, II purchased Lot One in 1985.
- Donald Hugh Daigle and Geraldine Daigle purchased Lot Two in 1998. A survey prepared for that purchase placed Lot Two’s western boundary at the centerline of Morris Road rather than at the centerline of the old roadbed.
- After learning of the Daigles’ survey, Griffin filed a petitory action seeking a declaratory judgment that his title extended to the centerline of the old New Hope‑Whitaker Springs Road roadbed.

## Issues

1. When a 1941 partition and later conveyances describe a boundary as the “public road” and later as the “public road (New Hope‑Whitaker),” does that boundary refer to the old New Hope‑Whitaker Springs Road roadbed or to the relocated traveled way known as Morris Road?
2. Does relocation of a public road before or after a conveyance automatically shift a deed boundary that uses a road as a limit of title, absent clear language showing an intent to follow the relocated road?

## Decision

- The court of appeal reversed the trial court judgment that had treated Morris Road as the boundary.
- The court held that the “public road” boundary references, read with the partition sketch and the consistent “public road (New Hope‑Whitaker)” language in Griffin’s chain of title, identified the old New Hope‑Whitaker Springs Road roadbed as the intended boundary in the disputed area.
- The court rendered judgment recognizing Griffin’s ownership extending to the centerline of the old roadbed and remanded for further proceedings consistent with that boundary determination.

## Legal Principles

- Boundary language in a partition or deed is construed to identify the specific boundary feature intended by the parties at the time of the instrument, considering the instrument as a whole and the context shown by the public records.
- When a description uses a “public road” as a boundary and the evidence shows more than one possible road alignment, courts look to clarifying language in the chain of title, attached plats or sketches, and related title history to determine which road was meant.
- A boundary fixed by reference to a particular road does not shift merely because the public later uses, improves, or relocates a roadway; moving the traveled way does not change a preexisting title boundary unless the instruments show an intent for the boundary to move with the road.
- Under Louisiana boundary rules, when property is described as bounded by a public road, title is generally construed to extend to the centerline of the road used as the boundary, unless the act provides otherwise.

## Conclusion

Griffin v. Daigle held that the “public road” boundary established in the 1941 partition and clarified in later deeds as the “public road (New Hope‑Whitaker)” referred to the old New Hope‑Whitaker Springs Road roadbed in the area where Morris Road had been shifted west, so Griffin’s title extended to the centerline of the old roadbed rather than to the centerline of Morris Road.


Griffin v. Daigle, 769 So. 2d 720 (2000)