The City of Virginia v. Mitchell

After bench trial court found Defendant liable for city code violations as to vacant building. City failed to proved that Defendant was owner of property during time period of alleged violations. At trial Defendant presented quitclaim deed conveying property from Defendant to another person, whose testimony was sufficient to authenticate quitclaim deed as instrument of conveyance of property. Deed's reference to "road" instead of "street" was insufficient to declare deed void for uncertainty, as address and parcel ID number in deed made identification of property conveyed readily apparent. That grantee paid no consideration for property is irrelevant to whether deed is void. (STEIGMANN and APPLETON, concurring.)