Arizona Revised Statutes

Ariz. Rev. Stat. § 9-254 (2026)

Title to streets

✓ current as of May 2026
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Upon filing a map or plat, the fee of the streets, alleys, avenues, highways, parks and other parcels of ground reserved therein to the use of the public vests in the town, in trust, for the uses therein expressed. If the town is not incorporated, then the fee vests in the county until the town becomes incorporated.

Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1966–2021 · leading case: Pleak v. Entrada Prop. Owners' Ass'n, 73 P.3d 602 (Ariz. Ct. App. 2003).
Pleak v. Entrada Prop. Owners' Ass'n, 73 P.3d 602 (Ariz. Ct. App. 2003). · cites it 10× “§ 32-2101(54) (defining “subdivision”), but contend the survey fulfills the requirements of AR.S. § 9-254. That section provides: Upon filing a map or plat, the fee of the streets, alleys, avenues, highways, parks and other parcels of ground reserved therein to the use of the…”
State Ex Rel. Herman v. Cardon, 544 P.2d 657 (Ariz. 1976). · cites it 2× “§ 18-201, the board of supervisors of a county may establish, alter and abandon highways in the county on the presentation of a petition signed by ten or more resident taxpayers of the county.”
Smith v. Beesley, 247 P.3d 548 (Ariz. Ct. App. 2011). · cites it 2× “Former § 16-231 is found at A.R.S. § 9-254. 5 . The former § 16-231 was codified in chapter 16, article 2 of the 1939 Arizona Code, which related to the incorporation, governance, and powers of cities and towns.”
Palmer v. City of Phoenix, 393 P.3d 938 (Ariz. Ct. App. 2017). · cites it 2× “What is now A.R.S. § 9-254 (2008) and (1956), which vests the fee of platted property in trust for the public’s use, existed as § 16-231 in the 1939 Civil Code, § 396 in the 1928 Civil Code, and, as discussed, § 1895 in the 1913 Civil Code.”
Moeur v. City of Tempe, 412 P.2d 878 (Ariz. Ct. App. 1966). · cites it 2× “The applicable statute, forerunner of our present statute A.R.S. § 9-254, is Para. 611 of the Revised Statutes of Arizona, 1901.”
Pleak v. Entrada Prop. Owners' Ass'n, 87 P.3d 831 (Ariz. 2004). · cites it 3× “See A.R.S. § 9-254 (providing that upon filing of a map or plat for a town, the "fee of streets .”
City of Bisbee v. Arizona Water Co., 153 P.3d 389 (Ariz. Ct. App. 2007). “” Section 9-254, A.R.S., adopted in 1901, states: “Upon filing a map or plat, the fee of the streets, aUeys, avenues, highways, parks and other parcels of ground reserved therein to the use of the public vests in the town, in trust, for the uses therein expressed.”
City of Scottsdale v. Mocho, 444 P.2d 437 (Ariz. Ct. App. 1968). “The appropriate sections of the Arizona Revised Statutes are as follows: “§ 9-254. Upon filing a map or plat, the fee of the streets, alleys, avenues, highways, parks and other parcels of ground reserved therein to the use of the public vests in the town, in trust, for the uses…”
Pleak v. Entrada (Ariz. Ct. App. 2003). · cites it 10× “§ 32-2101(54) (defining “subdivision”), but contend the survey fulfills the requirements of A.R.S. § 9-254. That section provides: Upon filing a map or plat, the fee of the streets, alleys, avenues, highways, parks and other parcels of ground reserved therein to the use of the…”
Pleak v. Entrada Prop. Owners'ass'n, 87 P.3d 831 (Ariz. 2004). · cites it 3× “[2] See A.R.S. § 9-254 (providing that upon filing of a map or plat for a town, the "fee of streets.”
Tms v. Zachariah (Ariz. Ct. App. 2021). · cites it 2× “A.R.S. § 9-254. That method is not at issue in this case.”
Tms v. Zachariah (Ariz. Ct. App. 2021). · cites it 2× “A.R.S. § 9-254. That method is not at issue in this case.”
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