Supreme Court of Maryland
Cty. Comm'rs, St. Mary's Cty. v. Aiken
June 20, 2023483 Md. 590
Summary
The court affirmed that the County holds fee simple absolute title to the disputed property because the 1945 deed unambiguously conveyed all of the land to the State forever in fee simple and created no limitation, easement, or reversionary interest. The court also held that the deed and recorded plats constituted an offer to dedicate the property for public use, that the State accepted the offer, and that the 1988 conveyance transferred the property to the County as part of a public county road. The court affirmed the remand for further proceedings while directing the circuit court to consider the County's 2017 ordinance closing the road.