Gagnon v. Board of Trustees of the Internal Improvement Fund

PATTERSON, Judge.

Donald Gagnon appeals from the trial court’s dismissal of his action to quiet title for having failed to exhaust his administrative remedies. We reverse.

This case involves chapter 8537, Laws of Florida (1921), commonly referred to as the “Butler Act,” later codified as section 271.01, Florida Statutes (repealed by implication 1951, expressly repealed 1957). The Butler Act granted title to submerged lands to riparian owners when those submerged lands had been bulkheaded, filled in, or permanently improved. The grant of title can run from *815the high water mark to the nearest…