Last Updated on July 5, 2021 by Lawrence Berezin
Metes and bounds description of the place of occurrence can be a true friend of the NYC driving public
If ignored, a metes and bounds description can be like the pit of misery.
I absolutely love the Bud Light commercials where the king gets presents from his adoring countrymen. The first two people in line give the king his beloved Bud Light. But, the third guy offers a special bottle of wine and is immediately escorted to the pit of misery. Dilly Dilly.
Are you a true friend of the Evil Empire? Of course not!
Then why do you grimace when you see a metes and bounds description entered on a parking ticket and ignore it? Personally, I smile because it can be a great way to beat a parking ticket.
Let’s start from the beginning
There are three ways to describe a place of occurrence (your parking space):
- Metes and Bounds
The first two ways are easy to understand. But, a metes and bounds description can make eyes roll because you may not understand how to translate it. Here’s a parking ticket with a metes and bounds description [click to enlarge]:
E/S Jackson Ave_20 ft S/of 44th DR in Queens means:
East Side of Jackson Avenue, 20 feet South of 44th Drive (Queens). Pretty easy, right? But:
- How do you figure out whether the description is correct?
- If it is misdescribed, how do you prove it?
Larry’s resources of choice
The DOT Parking Regulations Map (Text Version)
Google Maps Street View
Easy-step-by-step guide to a metes and bounds description defense
[Click on image to enlarge]
Translate the metes and bounds description
E/S Jackson Ave_20 ft S/of 44th DR in Queens = East Side of Jackson Avenue, 20 feet South of 44th Drive in Queens.
Locate Jackson Avenue and 44th Drive, Queens, on Google Maps Street View
What is the next street that intersects with Jackson Avenue and 44th Drive? Purvis Street
What is the next street that intersects with Jackson Avenue and 44th Drive in the opposite direction from Purvis Street? Court Square
Go to the DOT parking regulations map and plug-in the variables were called for with your parking ticket.
- Jackson Avenue
- 44th Drive
- Purvis Street and click
- Jackson Avenue
- 44th Drive
- Court Square and click
You’ll learn whether the sides of the streets run North-South or East-West. In this case, you win because the East Side (E/S) of Jackson Street does not exist.
Hopefully, in your case, the answer will prove the Warrior screwed up and misdescribed the sides of the street
How to prepare your defense certification and exhibits
Here’s a template to follow for your defense certification;
Dear Honorable Judge,
I hereby certify as follows:
I plead not guilty to this parking violation because:
-The Place of Occurrence was misdescribed
The TEA entered, “E/S Jackson Avenue_20’ S of 44th Drive in Queens.” The East Side of Jackson Avenue does not exist
I have submitted a series of exhibits in support of my defense.
Due to this circumstances, please dismiss this parking ticket.
-I hereby certify that my testimony is the truth to the best of my knowledge.I fully understand that if my testimony is willfully false, I am subject to punishment
-I certify that the images of the parking ticket, DOT Parking Regulations Map (text version), and Google Maps Street View are true and accurate reproductions of the originals as they existed on the date/time this parking ticket was issued.
I suggest you make screen grabs of the four exhibits above, but to the specifications and details of your parking ticket case.
How do you fare fighting fire hydrant parking tickets? Need a refresher? Click here. to learn five mistakes to avoid at all costs.
Bob: “That was one hell of a touchdown!”