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iephen Y Imashiro Richard Wurdeman
Mayor ~ - Corporation Coumd
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OFFICE OF THE CORPORATION COUNSEL
(01 Aupuni Street. Suite }25 • Hilo, Hawaii 96720A262 • (808) 961-8251 • Faz (808) 961.8622
20 August 1996
OPINION NO. 96-05
MS. DONNA FAYE K. KIYOSAKI
Director, Public Works
25 Aupuni Street
Hilo, Hawaii 96720
SUBJECT: PAPER ROADS
Dear Ms. Kiyosaki:
This office continues to receive requests from the Department of
Public Works requesting opinions on the ownership of roads.
Some of these roads are true "paper" roads, in that they appear
on maps but have never been used as roads. Others are old roads
which have fallen into disuse and disrepair. Still others, are
private roads which have long been in public use. The factual
variations are infinite, and too often the factual history is
not readily available, without extensive research. Although
there may be special circumstances that affect individual roads,
the following general principles apply.
I. Public Highways
Undez the terms of the Highways Act of 1892. (Act 47 of 1892)
all roads existing at that time, were declared to .be public
highways, and title thereto was vested in the Government. In Re
Aonlication of Kellev, 50 Haw. 567 (1968).
In addition, all roads, alleys, streets, ways, lanes, bikeways,
and bridges opened, laid out, or built by either the
Territorial, State or County Governments since 1892, are public
highways. HRS §264-1. All such highways are county highways,
unless they have been designated to the part of the State
Highway System by the Director of Transportation. HRS §264-41,
42, Santos v. Perreira, 2 Haw. App. 387 (1982) ~j
Comm. No._ 2
Ref. Toh~~~rM ~
Ref. Date
Ms. Donna Faye K. Kiyosaki
2J September 1996
Page 2
Although, under former law title to the rights of way for all
public highways was vested in the Territory or State, In Re
American Suaar Co. 29 Haw 820 (1927), title to all County
Highways was transferred to the Counties by virtue of Act 221
(1965), now part of HRS §264-2.
II. Private Highways
Those roads, alleys, and streets built, laid out, or opened by
private parties, become public highways only when they are
surrendered or dedicated to public use. This surrender or
dedication may occur either by deed of conveyance, or when the
private owner has not ezercised any act of ownership for five
years. In all such cases, however, the road does not become a
county highway unless it is accepted by the Council, HRS
§264-1. A road so dedicated, but not accepted, remains the
property of the dedicator, but subject to some prescriptive
right by the public, Territory v. Ala Moana Gardens 39 Haw. 517
(1952); Citv and County of Moan Inv Co., 1 Haw. App. 52 (1980),
and, until acceptance, remain "roads in limbo".
III. Paper Roads
The much used term "paper roads" has become a catch all,
describing all sorts of unused or abandoned roads. The true
meaning, as we understand it to be, is roads which were laid out
on a map, such as a subdivision plat, but which are never
developed or used.
Such roads, in our opinion, remain the property of the
dedicator, although subject to an encumbrance that they be kept
free of alterations which would prevent statutory dedication.
City and County v Boulevard Prover ie 55 Haw. 305 (1973).
This type of implied dedication, therefore, although divesting
the landowner of the freedom to develop the property does not
shift the responsibility of maintenance, or of title.
IV. Summary
We hope that this attempt to analyze this complez and often
controversial subject will be of assistance. We wish to
reiterate, however, that on any particular road, the factual
history surrounding that road is critical. At times, the
absence of such facts may make application of the applicable
legal principles impossible. For ezample, was the road in
question ever used as a vehicular right of way or is it a trail,
and thus subject to the jurisdiction of the State Department of
Donna Faye K. Kiyosaki
20 September 1996
Page 3
Land and Natural Resources. HRS §264-1(b). In other Cases,
such as those involving "homestead" roads (rights of ways
retained by the government as part of the program of land
distribution authorized by the Homestead Act of 1895), no one
may know whether the road was ever put into use, (and is thus a
County Road), or whether it is in fact a "paper' road.
In all such cases, however, we recommend that insistence on
legalistic technicalities should not be our accepted policy, but
that the welfare of concerned members of the public provide the
guidance to resolve difficult cases.
Sincer ly,
. WURDEMAN
Corporation Counsel
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DEPARTMENT OF LAND AND NATURAL RESOURCES ~~sr°R;c PAESERVa.~oN
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HONOLULU, HAWAII 96809
October 13, 1999
Ref LD-DSM
The Honorable Stephen Yamashiro
Mayor
County of Hawaii
25 Aupuni Street, Room 215
Hilq Hawaii 96720
Dear Mayor Yamashiro:
Subject: Legal Interpretation of the Definition of "Public Highway" under Sectio?
264-1(a), Hawaii Revised Statutes (HRS)
This letter provides you and your staff with an update on the State's position with regard
to paper roads under the definition of "public highways" pursuant to §264-1(a), HRS.
In the past, the Department considered paper roads unencumbered State lands under the
jurisdiction of the Board of Land and Natural Resources (BLNR). The Department has recently
amended its position on paper roads after consulting with the Department of Attorney General
(DAG). We now are of the view that homestead paper roads are public highways which have
been laid out by the government and fall under §264-I(a), HRS.
In their opinion of July 21, 1999 (attached), the DAG concluded that "a paper road which
has been delineated or laid out on a subdivision map and originally created by either the State or
a county, is a public highway, and, in general, is owned by the county in which the highway
lies." Thus, in most instances, the homestead paper road would be a county public highway.
The DAG went on to advise us that the BLNR should no longer grant easements over county
public highways, including paper roads, and that applicants should be referred to the respective
county for appropriate action.
Consequently, we would like to inform you that the BLNR will ?o longer issue
easements, deeds or other conveyance instruments for county paper roads. We may, however,
make an exception where the issuance of a quitclaim deed by the BLNR is specifically requested
by the county and required to clear title for the conveyance of the road from the county to a
private party. Accordingly, proceeds from the sale of abandoned county public highways may be
retained by the county pursuant to §264-3, HRS.
The Honorable Stephen Yamashiro
October 13, 1999
Page 2
If you have any questions regarding the above, please feel free to contact Land Division
administrator, Dean Uchida, at 587-0446 or Deputy Attorney General, Ms. Dawn Chang, at 587-
2993.
Thank you.
Very Truly Yours,
~„c.a/
- TIMOT E. JOHNS
Chairperson
Enclosure
cc: Public Works Department
Corporation Counsel
T
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BENJAMIN J. CAYETANO R~
GOVERNOR - ~ ~ 4TTORNEV GENERA~~x
1
THOMAS R. KELLER
P qST DEPUTY ATTORNEY GENERq~
STATE OF HAWAII
DEPARTMENT OFTHE ATTORNEY GENERAL
LANDlTRANSPORTATION DMSION
ROOM 300, KEKUANAO'A R W LDING
465 SOUTH KING STREE7
HONOLUW, HAWAII 96813
_
July 21, 1999
The Honorable Timothy E. Johns -
Chairperson of the Board of
Land and Natural Resources
1151 Punchbowl Street
Honolulu, Hawaii 96813
Dear Mr. Johns:
Re: Request for Legal Interpretation of the Definition of
"Public Highway" under HRS 264-1 (a)
THE QUESTION
This is in response to your predecessor's May 6, 1998
memorandum asking whether the Board of Land and Natural Resources
(BLNR) may sell an access easement over a "paper road."' To put
it another way, the question is, does the BLNR own paper roads,
pursuant to Hawaii Revised Statutes (HRS) § 264-2, so that it may
dispose of said roads under § 171-13, HRS.
1 For purposes of this opinion, the term "paper road" means a road which
has been planned by the government for the purpose of providing access to a
government created homestead lot, but does not actually exists on the ground.
Often paper roads are shown on subdivision maps.
The Honorable Timothy E. Johns
July 21, 1999
Page 2
BP.IEF ANSWER
In brief, we conclude that a paper road which has been
delineated or laid out on a subdivision map and originally
created by either the State or a county, is a public highway, and
in general,' is owned by the county in which the highway lies.
Thus, in most instances, the county, not BLNR has jurisdiction to
disDOSe of the road.
BACKGROUND
The question of how to treat a paper road under § 204-1,
HRS, has arisen from time to time when the BLNR has been asked
to grant a property owner an easement over a paper road on public
land for access to the property owner's lot. The matter
generally arises in the context of a request by homestead
subdivision lot owner for an access easement from the State over
the paper road in order to qualify for financing for a residence_
Financial institutions cenerally require a homestead lot to have
access to a public highway before the applicant may qualify for a
mortgage. Historically, the BLNR has granted to homestead lot
owners easements fir access purposes over these paper roads.
This action makes sense only if a paper road is not a county
"public highway" owned by the county and as such may be treated
as unencumbered state land subject to conveyance by the BLNR.
An ,example of the problem arose recently on the island of
Hawaii, where the government (State) created homestead lots on
state public lands for leases and fee simple homestead ownership,
pursuant to the Land Act of 1895 (Act). Section 212 of the Act
authorized the Commission of Public Lands' to survey and set
2We say "in general" because although the specific determination of
whether a paper road is owned by the State or county will be factually based
in each instance, almost all if not all homestead paper roads will be county
public highways.
'The Commission .~f Public Lands is the predecessor to the Board o` Land
and Natural Resources. Act 32, 1302 Haw. Sess. Laws. 95.
The Honorable Timothy E. Johns
July 21, 1999
Page 3
apart portions of public lands for homestead lots and roads. In
many instances, the government subdivided and sold the lots but
never constructed or built the planned roads that were intended
to connect the lots to a public highway. The roads, however,
were shown on subdivision maps created by the government.
In a memorandum dated June 8, 1992, we advised the Hawaii
District Land Agent that such a paper road was not a "public
highway" within the meaning of HRS ~ 264-1. We stated that in
order for a road to be a public highway the road had to exist on
the ground. Because of that conclusion, we further advised that
paper roads on the public land in question should be treated as
unencumbered state lands within the jurisdiction of the
Department of Land and Natural Resources, rather than public
highways subject to county jurisdiction. As such, the roadway
lands could be disposed of by the State.
For the reasons which follow, we reconsider the memorandum
of June 8, 1992, and conclude that homestead paper roads are
roads that have been "laid out" within the meaning of HRS ~ 264-1
and are thus "public highways." As to whether the spcific public
highway, (Kalaniauli Road, Olaa Summer Lots, Puna, Hawaii, TMK
3rd/1-9-03), is under the jurisdiction of the State or under the
jurisdiction of the county, we find that the road is owned by the
county and subject to its disposition, not the BLNR's.
DISCUSSION
A. Definition of Public Highway.
Hawaii Revised Statutes ~ 264-1, defines "public highway" as
follows:
(a) A11 roads, alleys, streets, ways, lanes, bikeways, and
bridges in the State, opened, laid out, or built by the
government are declared to be public highways. [Emphasis
added.]
The Honorable Timothy E. Johns
July 21, 1999
Page 4
The definition of public highways under HRS § 264-1(a), is
identical to the original definition of public highways found in
the Highways Act o` 1892. The terms "opened" and "built" in the
statute are apt to describe a road that actually has been built
and exists on the ground. The term "laid out," on the other
hand, is more likely to describe a road that has not been built
yet, but is intended to be built.
Zn order to ,certain the true meaning of a statute, we are
generally guided by canons of statutory interpretation. "[T]he
fundamental starting point is the language of the statute
.itself." Mathewson v. Aloha Airlines Inc., 82 Haw. 57, 71, 919
P.2d 969, 983 (1995).
When there is doubt, doubleness of meaning, or
indistinctiveness or uncertainty of an expression used in a
statute, an ambiguity exists. (citation omitted). And
fifth, in construing an ambiguous statute, the meaning of
the ambiguous words may be sought by examining the context,
with which the ambiguous words, phrases, and sentences may
be compared, in order to ascertain their true meaning.
Moreover, the courts may resort to extrinsic aids in
determining the legislative intent. (citation omitted).
Peterson v Hawaii Elec Liaht Co Inc 85 Haw. 322, 328, 944
P.2d 1265, 1271 (1997).
There is no statutory definition for the term "laid out."
The term "lay out," however, is defined in ordinary terms as
meaning "to plan in detail; to map out; to arrange as grounds or
plans. (Webster's New International Dictionary, 2d ed.,
unabridged, 1950.)" In the Matter of Bishop Trust Co Ltd., 40
Haw. 730, 732 (1955), reh'g denied, 41 Haw. 650 (1955).
In Bishop Trust, the Supreme Court of Hawaii, described the
term "laid out," as meaning a road which is "delineated on a map
or otherwise located and defined." Id., 40 Haw. at 732.
The Honorable Timothy E. Johns
July 21, 1999
Page 5
Similarly, in Watson v. Greely, 69 Ca1.App. 643, 232 P. 475
(CA 1924), the court distinguished roads that actually had been
built or constructed from roads which had only been "laid out."
In Watson, the definition of a "highway" under the relevant
statute was as follows:
In all counties of this state public highways are
roads, streets, alleys, lanes, courts, places, trails,
and bridges, laid out or erected as such by the public,
or if laid out or erected by others, dedicated or
abandoned to the public [.j
Id., 69 Ca1.App. at 649, 232 P. at 478. The court in
distinguishing between the two types of highways made the
following observation:'
[T]he words `laid out' do not in themselves imply the
building or construction of a structure or other work.
One about to build a house would not say that he
intended to `lay out' a house, much less would he say
after it was built or completed that it had been `laid
out.' Nor would those words be the apt ones to use in
expressing the idea of the building and completion of a
levee or a canal or a ditch. Hence, it is only
reasonable to assume that if the legislature, in
defining highways, intended to say that only such ways
as had roads upon them were county highways, it would
not have used the phrase "laid
out" as descriptive thereof, but would have said that
those ways only are highways upon and over which roads
have been built, and, naturally, would have employed
more apposite words or phrases in defining the same.
Id., 69 Cal.App. at 649-50, 232 P. at 478.
One might read the s~atute to mean that in order for a road
to be considered a public highway all three elements (opened,
_aid out, and built) must be satisfied. We do not agree with
The Honorable Timothy E. Johns
July 21, 1999
Page 6
this reading. The terms used to describe a public highway in HRS
§ 264-1, are "opened, laid out, or built." (Emphasis added). If
the legislature, when it enacted HRS § 264-1(a), had intended
that only highways which had actually been built could qual_fy as
public highways, it would not have used the disjunctive "or" to
set apart the three verbs listed in the definition of "public
highway." Moreover, there would have been no point to using the
term "laid out" in the statute if the term independently of the
other verbs in the section did not by itself mean "public
highway." If the statute intended to include only reads that had
in fact been constructed by the government, the term "laid out"
would be meaningless surplusage.
A cardinal rule of statutory construction is to give effect
to all parts of a statute so that no clause, sentence. cr word is
rendered superfluous, void, or insignificant if a construction
can be legitimately found which would give force to and preserve t, ~
all words of the statute. State v. Ortiz, 74 Haw. 343, 351-52,
845 P.2d 547, 551-52 (1993), recon. denied, 74 Haw. 650, 849 P.2d
81 (1993). To use the terms "laid out" and "built" in the
conjunctive would be redundant and would not give to "laid out" a
separate meaning.
Based upon the above, we are of the view that a road such as
the homestead paper road on the Big Island which has been
delineated on a subdivision map created by the government, falls
within the definition of "public highway" under HRS § 264-1(a),
even though the road does not exist on the ground.'
"Attorney General Opinion No. 63-54 states that a "public highway"
pursuant to § 142-1, Revised Laws of Hawaii 1955, which is the predecessor to
§ 264-1, HRS, "is a road or street actually constructed and existing on the
ground. It does not refer to a mere `paper' road or an unimproved way not
open to the general public as a road." We are now of the view that the
statement in AG Op. 6=-54 is incorrect, but because the discussion on the
status of paper roads was not relevant to the question posed in the opinion,
the statement does not. affec*_ the conclusion. reached in AG Op. 63-54, nor is
the statement control:..ing precedent in the present analysis.
The Honorable Timothy E. Johns
July 21, 1999
Page 7
B. Ownership and DisDOSition of Public HiQhwavs.
Public highways are of two types:
(1) State highways, which are all those under the
jurisdiction of the department of transportation; and
(2) County highways, which are all other public highways.
Section 264-1(a), HRS, defines two types of public highways. The
first consists of those public highways under the jurisdiction of
the Department of Transportation (DOT). These the statute
declares are state public highways. Section 264-1(a)(1), HRS.
State public highways are more particularly described in chapter
264. Generally they are federal aid highways which run around
the perimeter of each island. All other public highways are
county public highways. Section 264-1(a)(2), HRS. The counties
own in fee simple their respective county public highways by .
virtue of HRS § 264-2. In most, if not all cases a homestead
oaner road would nog fall under the jurisdiction of DOT.
accordingly, it would be a county public highway.
CONCLUSION
In view of the conclusion we have reached in this opinion,
°(...continued)
The question raised in AG Op. No. 63-54 was whether the County of Hawaii
could sell a state-established homestead paper road. The opinion concluded
that a county could not because it did own the highway under § 142-2, RLH.
Section 142-2, RLH, limited the ownership of county public highways to "only
such highways acquired by the counties by eminent domain, purchase, dedication -
or surrender." Since the count; had not acquired the paper `road' through any
of these means, the opinion rightly concluded that the county could not sell
it. Act 221, 1965 Haw. secs. Laws 338, amended § 142-2, to provid=_ that by
virtue of section 142-2, HRS, itself the county owns in fee simple all county
public highways acquired by whatever means and may dispose of them in
accordance with the laws.
The Honorable Timothy E. Johns
July 21, 1999
Page 8
we advise that the BLNR should no longer grant easements over -
county public highways (which include paper roads) to homestead
lots. Instead applicants should be referred to the county for
appropriate action.
Very m y yours,
' Chan
Deputy Attorne General
APPROVED:
~
Earl I. Anzai
Attorney Gene al !
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