Newton County, Mississippi v. Deerfield Estates Subdivision Property Owners Association, LLC

Summary

The court affirmed the chancery court’s judgment that Deerfield Lane and Lake View Drive became public county roads through express common-law dedication when the county board formally accepted them in its 2001 minutes. The failure to place the roads on the official map and road register did not invalidate that acceptance, because the board minutes remained the official record until the statutory recording occurred. The court also held that laches and the general three-year statute of limitations could not bar the subdivision’s declaratory-judgment claim because the county had not followed the statutory procedures for abandoning public roads.