Once they know where the boundary is located they can no longer move it because that would violate the Statute of Frauds.
If they have the line Surveyed (say it is a simple Survey) then fence it in another location they can't say they were uncertain therefore they have to accept the Surveyed line or do a Lot Line Adjustment which of course has to be written.
But if they never get the line Surveyed, they don't know where the boundary is located and they simply fence it with the intention of establishing their boundary then they will probably be held to that location in subjective uncertainty States.
I think I would prefer a system which is still optional but doesn't affect the rights of subsequent purchasers without constructive notice of the agreement, similar to recording Deeds. Recording of Deeds is optional but doing so brings with it advantages. It would be better, I think, if Boundaries were handled the same way. Go ahead and have your oral agreement but it is only effective between the parties to it (like Deeds) unless you commit it to writing and record it.
It's not a free for all like that. There are checks in the laws that restrict the application of boundary establishment. There are two different roles for a surveyor depending on whether the boundary is established or not established. This evidence must be gathered first to determine whether the established line is measured and reported or a new line to be established is staked out. Staking out the "record title" and showing occupation doesn't locate the boundary and can lead to disputes where there shouldn't be any in most cases. I don't believe this is beyond the capability of a professional. It might require some adjustment from the standard just show the facts survey.
The reason I favor establishment law and really like what the Utah court has done is to protect the established boundaries long in place from being disturbed. We have boundaries that have been in place for decades even a century. These shouldn't be subject to new section breakdowns and any of a dozen or so possible interpretations of the record title. These boundaries are not waiting to be established according to a modern survey as the boundary location and establishment is long behind us. It shouldn't take a court decision to keep these boundaries where they are and to also map them in the official records. The establishment tripped the second the requirements of the law where fulfilled. According to the law these boundaries are established and shouldn't be disturbed. These boundaries are the limits of the adjoining titles even if not in perfect mathematical alignment with the writings. Why does so many folks want to mess with them? How come so many folks want to mess with and deny these landowners their rights? What these landowners need is a mapping profession that applies the law and can map the established boundaries for the GIS and other public records. Landowners neither want or need someone to go around digging up old bones, kicking sleeping dogs and otherwise creating all kinds of chaos, disputes and very expensive fixes to a problem that really doesn't exist if the law is respected. They are sick of it! Don't think you can't be fired because the boss dislikes all the unnecessary problems you make.
The problem I am seeing in California is the urban areas drive the common law. We have a one-size-fits-all Doctrine that leads to sometimes bad results in newer urban areas where they shouldn't. For most of the century the agreement could be inferred from a lack of disagreement as to the established boundary. Attempting to make the requirements for what they viewed as a "last resort" Doctrine, our Supreme Court required proof of an agreement which in many cases is simply impossible to get, particularly in long acquiesced boundaries which most need protection.
Tightening up the standards of proof has led to conflicts between fences and an orchard that have been in place for Decades and Chapter 3 aliquot lines as in Martin v. Van Bergen being decided in favor of the measurements.
I think the Legislature could step in and craft a Statute which serves public policy needs better. Go back to the old standard of proof on the agreement while at the same time allowing property owners to agree to their boundary as they can now with no survey or writings but make it only effective between the parties to the agreement if the boundary is subjectively uncertain only so that they have an incentive to either record their agreement or commission a survey.
Dave,
While I agree with much of what you have stated, there is one area that has not been considered. While the landowner has rights, such as be able to settle an unknown boundary line with his willing neighbor, the landowners (including prospective purchasers) have obligations. They are bound by the actions of their predecessors with notice, which they are expected to question and investigate. I would assume the following two statements are true (or has been true) in California and most every state.
"One who purchases property is put on notice of title disputes that a reasonable investigation would reveal." Anderson v. Hayes, 145 Idaho 741, 743, 185 P.3d 253, 255 (2008).
A boundary which has been fixed through agreement or acquiescence is binding upon successors in interest with notice. Luce, 142 Idaho at 271, 127 P.3d at 174
As you can see the following quote is cited to a California case, so at least at some time in the past, it applied there as it exists here today.
"The fact that an accurate survey is possible is not conclusive of the question of whether a doubt exists as to the location of the boundary. The doubt may arise from the believed uncertainty which may be inferred from the circumstances surrounding the parties at the time the agreement is deemed to have been made, and if in good faith the parties resolve their doubt by fixing the location of the common boundary, it will be considered the boundary called for in the deed." York v. Horn, 154 Cal.App.2d 209, 315 P.2d 912, 915 (1957). Duff v. Seubert, 110 Idaho 865, 719 P.2d 1125 (1986)
While the common law may vary from state to state, some things are usually common. It is unfortunate for the citizens of California that the courts have made such a mess of such reasonably simply principles. I feel for you.
In Idaho a long standing fence has particular importance:
"For nearly a century it has been the law of this state that evidence of a long established fence creates two presumptions. First, when a fence line has been erected, and then coterminous landowners have treated that fence line as fixing the boundary between their properties "for such a length of time that neither ought to be allowed to deny the correctness of its location" the law presumes an agreement fixing that fence line as the boundary. . . . Second, coupled with the long existence and recognition of a fence as a boundary, "the want of any evidence as to the manner or circumstances of its original location, the law presumes that it was originally located as a boundary by agreement because of uncertainty or dispute as to the true line." Luce, 142 Idaho at 271-272, 127 P.3d at 174-75 (internal citations omitted).
Your statement:
This is not an analogy to dashed or protracted lines on a map. Rather, it would be like rejecting all the monuments BLM ever set in favor of wherever the adjoiners claim they agreed to today, or tomorrow, or yesterday, and they are free to change their minds on what they just said at any moment. There is no possible way to survey that. One must go to the courts to find out where the boundary is located under those circumstances. And, that court decision is no good a day after it is given because the landowners could go home and establish a different line that night.
This is not what is being discussed and is nowhere close to land surveying doctrines.
We are not talking about monumented boundaries and are talking about boundary lines that have been located on the ground and agreed to by the landowners. The only trouble is when a deed staker surveyor comes along and can/will only run out the deed calls.
The entire erroneous premise can be seen in the BLM resurvey and subsequent subdivision of section surveys, where only the aliquot part lines (deed lines) were run on the ground and completely ignored existing monumentation. Not only was established lines ignored, but monumented lines as well.
I think it is safe to assume that the neighbors were happy with their established monumented boundaries until BLM came along!
Just my opinion.
Keith
What blows my mind is those that can't see the reasonableness and common sense of all that especially the reference to a fence treated as a boundary that has been in place for a century. Why wouldn't it be a presumption that an agreement was in place as for a hundred years nobody objected! Talk about blinded by your deed, slide rule and transit!
I was trying to find your Luce case and got this one:
Huskinson v. Nelson Idaho 2012
After 60 years the court said a former cattle fence was an agreed boundary. Because of what the landowners DID during that period, treated it as a boundary.
Here is the Luce case:
This is a case where the court cites a lot of law with regards to boundary by agreement. The boundary by agreement is rejected as it doesn't meet the requirements of the law. So the case doesn't have to come out one way or the other for the cited law to be informative.
Well, because we don't need to presume to know that a 100 year old fence was built at or nearer to the time of the original survey. So the proper presumption would be that the parties tried to fence between the survey monuments, unless there is other historical evidence of the area that destroys that presumption. Proof of that presumption would be a fence that is within a foot or two of the line per a retracement survey. The parties were not particular about minimal differences and called it good enough. But no, I don't think it reasonable to presume the parties had uncertainty and an intent to settle it by an agreement to a new line unless there is some corroborating evidence or history or custom of the area to back up that presumption.
The laws regarding acquiesence indicating agreement are a legal fiction designed to allow the parties to settle on the fence at a much later time in order to avoid a costly court battle. However, if the surveyor can not convince the parties to reduce this agreement to writing and take that way out that is available, then it all falls apart. The reason for the law disappears as soon as the parties lawyer up. And, the law does not work well in the courtroom because of the lack of objective evidence, unless the fence is conclusive.
I agree a surveyor should know the law and follow it. It appears as if in Utah the surveyors job is to map the fences as the property lines and make the owners agree to in writing again, or fight for the true line if they so desire. But it strikes me that even the surveyors using the fences are not doing their job well. The decision posted awhile back does not seem to delineate where the boundary is in a retraceable manner. It just says the fence is the boundary, and gives two differing locations per the surveys (small but so is the difference they are fighting over). What is to stop one side or the other from moving it a little bit each year? It seems to me the surveyor should be locating each and every fence post in order to delineate where this boundary is located. If the parties are fighting over a foot between the end of the fence and a survey monument, they will also be fighting over variations in the fence.
Seems more sensible to me to retrace the original survey if possible. Give a prescriptive easement or something for use of the fence and/or maintenence agreements of some kind, or a shared cost to move it. It does not seem to me that the acquiesence law in Utah is helping to settle disputes out of court if you have all these recent decisions on the issue. It would be interesting to find out how many of these a surveyor was able to reduce to writing without court in the past several years.
I thought I successfully settled one of these last year, but the parties are at it again and it looks like they may go to court in spite of the agreement now in writing. People just have to have their day in court sometimes.
Usually the fight doesn't start until someone becomes convinced (oftentimes due to a survey) that the fence is not the boundary.
I've never heard of anybody inching a fence a little bit each year but I'm sure somewhere it's been tried. I have seen new fences built to one side of the old one just because they didn't want to bother tearing the old one down. Then the old fence does get tore down later. It's just part of what you need to look for.
In some respects maybe mapping the fences as boundaries is what is done. BUT it should only be done after the evidence has been gathered to support that the fence IS on the boundary. If the fence IS the monument why wouldn't it be shown as the boundary.
I'd say the mapping and describing every post is a bit over the top but I'm sure someone could make that argument. If a landowner thinks they need protection from inching the fence over then I suppose you'd need that. Otherwise the fence (or other) physically standing makes quite a good and visible boundary marker.
The problem of mapping the record v. the real world is one I'm trying to sort out. I don't think that an agreement needs to be reduced to writing to make it effective. But if the writings are going to be considered gospel then the location of the boundary needs to properly get into at least the mapping records so it shows properly especially these days when folks are using the GIS and instant computer access.
One way might be through affidavits. Affidavits could be recorded by the parties with reference to the established boundary. These would have the descriptions of their parcels so they would get indexed in the title records and then would have the surveyed description of the established boundary line. Then the GIS maps could be updated to show the actual location of the boundary. There would be no conveyance of land as according to the law their is no conveyance of land due to the establishment of the location of the boundary. The title description of land would remain intact and unchanged but the mapping of the boundaries would be correct.
Did you read the Huskinson v. Nelson case from Idaho I linked below? The court rejected the idea that the proof of an initial agreement was required after a long period of time. What the parties DID later is the proof of acquiescence and an implied agreement. The fence was just a pasture fence in the middle of a single ownership to begin with. It's the same way in Utah if you treat a fence as a boundary for at least twenty years or even if you don't raise objections as to whether the fence is the boundary it will be considered as an agreement that the fence is the boundary. Maybe this is just one side of the varying views in different states as to establishment law. Everyone must understand the law in their state.
TX apparently has an uncertainty requirement in its doctrine of boundary by agreement. Even though the Myerses pursued boundary by adverse possession it demonstrates TX has boundary doctrines associated with occupation and agreement which I suspect any TX surveyor should consider in making a boundary determination.
Myers v Wright Court of Appeals, Dallas TX
In 1972, the Myerses bought a residential lot in Denison, Texas, which they did not survey. ? A barbed wire fence separated the Myerses' lot from Carter Kent Boyett's lot adjacent to the east. ? In 1978, the Myerses removed the barbed wire and replaced it with a chain link fence.
The Myerses also counterclaimed for “common boundary line ? by agreement or by acquiescence” and pleaded the “Doctrine of Agreed Common Boundary Line.”
the Myerses failed to produce any evidence as to the uncertainty element of their claim for “boundary by agreement” challenged on no-evidence grounds. Nor do they raise any issue on appeal as to their claim for an agreed common boundary line. ? We conclude they have waived this claim. ?
a claimant may substantially modify a casual fence and so change its character that the fenced-in area becomes a designed enclosure. ?Rhodes v. Cahill, 802 S.W.2d 643, 646 (Tex.1990); ?McAllister v. Samuels, 857 S.W.2d 768, 777 (Tex.App.-Houston [14th Dist.] 1993, no writ); ?Butler v. Hanson, 432 S.W.2d 559, 563-64 (Tex.Civ.App.-El Paso 1968), rev'd on other grounds, 455 S.W.2d 942 (Tex.1970).
Myers's affidavit testimony that he replaced the barbed wire fence with a chain link fence raises a fact issue whether the Myerses substantially modified the fence so as to change its character that it was no longer a casual fence. ? See, e.g., Butler, 432 S.W.2d at 562-63.
Having concluded the Myerses produced evidence raising fact issues on their intention to hold the disputed property adversely and notice of hostile possession, we resolve the Myerses' four issues regarding their claims pursuant to the ten and twenty-five year statutes of limitation in their favor. ?
Baily v Gillard Tx court of Appeals
Gillard had purchased his tract of land in 2005 from Barbara Taylor who, along with her late husband Patrick Taylor, had owned the land since the early 1970s. ? When they purchased the land, they did not have a survey done, but relied on what the prior owner had told them in determining the property line. ? Based on the prior owner's representation, the Taylors put up a fence at the property line
it is unnecessary to show the Taylors or Gillard had the intent to dispossess a rightful owner, but only that they intend to possess the land to the exclusion of others. ? See Tran v. Macha, 213 S.W.3d 913, 915 (Tex.2006). ? Clearly, when the Taylors put the fence up, they intended to claim ownership to the tract now in dispute to the exclusion of all others. ? The Taylors and Gillards claimed open and exclusive ownership of the land for in excess of ten years.2 ?We conclude the evidence is sufficient to show Gillard's title to the property by limitations. ? We resolve the first and second issues against appellants.
Since my experience was with BLM as a land surveyor, we did not have the ability to make an agreement with the land owner on the boundary location. After talking with the landowners, we would make the judgement on the fences and if we agreed that they were considered the boundary and not just a fence of convenience, we would set monuments at the fence corners.
Thus, monuments and a survey plat would establish the boundaries between private and Federal land. Obviously, we could not set monuments to define boundaries between private and private land.
What I fail to see, is the fact that if the private land surveyor (not a deed staker), talked with the land owners and it was understood that a fence was the boundary; why wouldn't the setting of a monument at the fence corner, be sufficient to memorialize the boundary. The monument and the filed survey plat should be sufficient?
The alternative of course, is to survey the protracted lines on the ground and ignore all existing forms of boundary evidence. Fences and occupation be damned!
And then of course, every few years and another surveyor (deed staker) will have a little more precise measurement of where those protracted lines are and set another monument.
And we wonder why some landowners do not like surveyors!
Keith
I didn't read the Idaho decision, but I'm familiar with what it probably says. NY law is similar and in fact many of the early decisions in the western states cite NY cases and built their law based on what had already been decided in states that developed earlier. There are really very few local twists on these things and they tend to come down to he said she said, regardless of the local variations of the law. I guess that's my problem with the whole theory. It was a great tool in development of the country and settlement of disputes some years after development. But I think its time has passed and there are more reasonable solutions that could be developed that would be less costly, more predictable, and have more permanance.
I don't want to take away the right of landowners to settle uncertain boundaries. On the contrary I would like to give them access to a better method to do so.
In addition, I think many of these so-called boundaries disputes are really over who has what rights or ownership in the fence (or other improvement) itself. Who can take it down, modify it, pay for maintenance, etc.. This real root of the dispute could be addressed without moving a retraceable original record line.
At least in the rural portions of the Inter mountain West we are still in the early stages of land development. Many areas were patented and after that not all that much precise attention was given to locating the boundaries. In my county there is no records of the county surveyor keeping track of PLSS corners and there certainly is no money at this time for doing so. But the landowners established their boundaries, they somehow measured something from somewhere and fenced and occupied it for all these decades from there (most of it is reasonably OK). Most of these agreements are long in place but modern title and surveying wants to fix it to how it should have been and not how it is. From my view the simplest way is to recognize the law and what has already occurred. We just need to get it properly mapped and somehow stop the continual trying to make the old records math fit on the ground. It's like trying to pound a square peg into an irregular polygon hole. It just doesn't fit no matter how may times the numbers are crunched.
Well, modern boundary by acquiesence is also trying to pound a square peg into a round hole. The courts can not agree with a certain set of facts and you expect a surveyor to resolve the whole thing? Why is the fence not given the presumption in the Luce case? Who is that idiot surveyor who surveyed the deed for Marble? The law is clear and surveyors only have to know it? Idaho law = a fence is an agreed boundary except when it isn't, and it isn't even in circumstances we have previously said it is, except if we believe the next witness that some enterprising attorney found stationed at the south pole and was able to get an affidavit from which changed our mind until he was transported here for court and he testified to something different than in the affidavit.
Surveyors do not cause these problems and they can't solve them by knowing the law. Surveyors can only try to get the parties to put something in writing. If that fails, the surveyor must show the retraced line and the area of dispute.
I think once the facts are decided and the law applied it's fairly clean from there. Maybe sorting out the facts can be difficult but who as a professional should this work be given to. Surveyors are the logical choice from my view.
I agree that surveyors should try and get the record updated and especially the modern boundary mapping. This needs to get it right so that it doesn't become a misleading issue as far as the public is concerned (seeing the lines in the GIS different from where they actually are).
As far as what to do when the surveyor can't get the mess straightened out. Maybe the surveyor shouldn't make a mess where there actually isn't one (establishment is long settled). As far as gathering the evidence and disclosing the facts, yes that needs to be done and a surveyor is best qualified to do that. As far as showing the record title as the boundary and the occupation (probable establishment) as a possible alternative I disagree with that. If the surveyor can't make a pretty solid determination of where the boundary is they should acknowledge that also (sorry folks there are issues here I can't resolve, but I can help you). If the deed or record title line or whatever isn't the actual boundary it shouldn't be shown as that. If I can't determine the boundary I shouldn't represent one of the possible choices as the boundary and send them into litigation to see if I'm right. If the landowners can't settle it I recognize that I as a surveyor can't adjudicate it for them. In fact I can never adjudicate the boundary.
I think in the end we want the same thing, stable boundaries and proper mapping. We just have our different ways of looking at it. That's why I'm here. I want to try and understand all the different ways of looking at the issue. I'm about ready to try and get some legislation going in Utah to deal with the mess. I need to be prepared for all the questions and different viewpoints if I'm to actually accomplish something worthwhile and benefit the states landowners and protect their rights. If I can't do that I shouldn't try to do it at all.
So thanks for the discussion and your input and views. That allows me to learn and prepare.
To me the common law and all it's long term consideration and wisdom makes total sense. To others maybe the common law just has it all wrong and is a bad way to do things. I don't want to interfere with the common law as some others in Utah do and have. I'd like to see the common laws solution to these problems recognized and applied.
Your statement:
". . . a retraceable original record line. . ."
Again, I am assuming at least in the PLSS, this line is the protracted dashed lines on the original survey plat.
And of course they are retraceable, but not with the bogus theory of using them for the sole evidence of boundaries within the section.
I have to imagine that in almost every case, these lines are possible to locate on the ground, even with many lost original corner monuments that can be reproduced by proportionate methods.
And of course, all fences and lines of occupation can simply be ignored!
What is wrong with my suggestion, that if in fact the fence corner is accepted by the landowners; why can't the private surveyor set a monument at the fence corner and record the survey?
Why would an agreement document be necessary?
Keith
"Why would an agreement document be necessary?"
That's where you get into the thick of it. The title industry and the recorders don't know what to do with it. Surveys in my state are not recorded in the title records they are filed in the county surveyors records. Surveys don't affect title they just show location of boundaries. So it doesn't get mapped for tax purposes and the GIS and everything else. They don't know how to map it or they just won't map anything other than the title records.
Well, we all know the math including protracted lines from the title records does not make a proper and accurate map of the reality on the ground. One GIS in Utah even has two separate layers, one for title (including millions of gaps and overlaps) and another for surveys and I suppose rubber-band parcel polygons (fits together - sort of).
So how do you get the location of boundaries mapped properly when those in control insist that the title records absolutely define boundary location. In other words the square peg must be forced into the irregular physical polygon hole. Hell, the deeds say so, so it must be correct! If you live and work in a virtual world of title papers and the math you can derive from them why would the physical world not need to conform to your belief's?
So if a landowner needs title insurance or to make a land use application or subdivision you run into being forced into a complicated fix to a problem that really doesn't exist. Forcing your title record's and boundary location to mathematically be the same. The big gun is quit claim deeds. You can fix anything with quit claim deeds if everyone will sign. You can have your long established boundary if your neighbor will quit claim it to you.
Looks like a bigger problem than it should be!!
I was trying to capture the largest possible sample of situations with my statement. Not limited to anything in particular, but rather encompassing any retracement. The only requirement is that the line has actually been surveyed in the past. By survey I mean any marking of the line by engineers, surveyors, the parties themselves. These markings hold (not considering adverse possession or unwritten agreements) unless they wander over senior title lines.
Part of the reason for much of the trouble is a failure of surveyors to be able to perform reasonable retracement work. I think that is what you are getting at also.
If surveyors are putting pins one foot away from an ancient fence built at or near the time of the original survey, based on measurement from some other far removed monument or some proportioning scheme, then it is not a boundary agreement we need, it is valid opinion of the original line that is needed (probably best represented by the fence in most jurisdictions). If the history of the area does not indicate fences were built along property boundaries, then we would have to take that into consideration. In addition, interior lines within sections in the PLSS may be more inclined to be agreed lines (no survey existed to base the fence on).
If surveyors can't find enough evidence and know enough law to perform retracement surveys that agree with one another in most instances; how in tarnation could they handle the much more difficult task of gathering enough evidence and knowing enough law to determine an agreed boundary? It just doesn't make sense to me.
I don't think there's a snowballs chance in heck of passing legislation allowing surveyors to make the determination of title based on agreed boundaries (yes, yes I know agreed boundaries don't convey title). But boundaries are physical limits of title, and other industries have a vested interest in making sure they are fixed rather than moveable at the whim of the landowners. This takes a writing and if the parties refuse then they should be required to go to court and have the court write it for them, or declare the unwritten agreement does not exist as the case may be.
A unilateral marking on a map by one surveyor, of an apparent agreed boundary, without written agreement by the parties affected, is merely a dispute waiting to happen. It resolves nothing. In fact it hides the situation so that a prospective party who might be affected by it may believe in the wrong line and fail to fully discover the situation until after they have become economically involved. A retracement opinion is different because it does not claim agreement and settlement of the line in question.
I like agreed boundaries, I just don't like agreed boundaries that nobody agrees with. And I have rarely seen one that the adjoiners agree with. Over time, unwritten agreements fall apart. That is why a writing is required, and the original statutes concerning it were called the statute against frauds.
I think surveyors should get involved and help write better statutes to deal with boundary problems. But putting unwritten agreements above written ones is not an improvement.
What I want is legislation that would enable landowners to record their agreements of acceptance of long established boundaries whether by agreement or acquiescence (in line with current common law). That sounds like a boundary line agreement right? Well, not in Utah because by statute a boundary line agreement has been defined as a boundary line adjustment that requires conveyance by quit claim deeds to a new line.
We have lots of folks like there is in the survey world that just don't believe that anyone is up to the task to deal with established boundaries that don't follow the record spot on. They want every agreement to be a quit claim conveyance and essentially for the common law solution to be wiped off the slate (like many here). Pay no attention to the Supreme Court, nobody can apply or understand what they say or do.
So common law agreements are fine in Utah until you want to place one in the record or have it mapped. At that point the whole former agreement is to be thrown in the trash and a new conveyance to a new boundary (same old one in place for decades). So landowners must "adjust" their boundary to make it remain in the established location. This is not without creating it's own set of problems. This year the legislature passed a bill to remove adjusting boundary lines from the regulation of zoning. Since adjusting boundaries is conveying land P&Z in many places said they had to be dealt with (application, review, fees etc.). This just didn't fly out in the rural community that has been "adjusting" their boundaries by quit claim deed to keep them stable for decades now. It was bad enough to need to quit claim to the neighbor every so often to avoid moving your improvements, but when you also had to make application, pay fees and get review from P&Z, well that was just to much. None of this would exist if everyone would just recognize the established boundaries and agreements recorded to memorialize them and map them. I can't get any traction with any of the legislators (I've tried) because well, I'm a surveyor. I'm looked at as the problem not the solution.
It wouldn't surprise me if a bill was introduced to eliminate the problem from their view, surveyors. The real problem is denial of the common law of established boundaries and surveyors have and are part of the problem but certainly not the only problem. The record title math is far from perfect, never will be perfect and trying to make it perfect by forcing it on to the ground will never solve the problem (just more adjustments). Surveyors should stop staking it out and the rest of the title industry and regulators should stop requiring them to do so. The courts figured it out a long, long time ago. The law is easily accessible due to Google search and all the other online resources. We can learn and apply the law, it's time for the denial or our responsibility as surveyors to stop.
