the California Courts have ruled that a metes and bounds description presumes there was a survey. It is a logical conclusion that survey measurements (direction and distance to monuments) came from a survey.
This appears to leave the street in the hands of the original grantor which is a result contrary to good policy since disputes can arise decades after the original grantor is long gone so the Courts will waste a lot of time trying to solve the case. See the dissenting opinion in Burk vs Squiers. This paragraph is more a comment on what the law should be than what it actually is, Courts sometimes don't adequately consider the consequences of their common law rule making.
It would be interesting to see if the Vermont Courts have weighed in on this rule more recently, they declined to follow it in the 1974 case I posted above.
@dave-karoly Dave, here's the link I posted above in my initial response to the "decided law" cry. 2017. https://caselaw.findlaw.com/vt-supreme-court/1858127.html
@ashton My opinion, for what its worth, is that we (you) can use the subsequent deeds written by Wheeler to inform about his intent when describing C. As I see it, he thought the Town owned it in fee (although many don't even consider "ownership" of a road) and ultimately created an orphaned strip at which point the doctrine-of-the-centerline would apply. If A's or B's deeds had included the road, they would only reinforce the intent of C's deed. But they don't, they only point out that Wheeler didn't know what to do with the road. Absent deeds A & B, I'd ask Wheeler
