Machado v. Ryan
Annotate this CaseJerry and Terry Machado (the Machados) and Richard Clifton appealed a district court's decision finding that their properties were burdened by an express easement and an implied easement by necessity in favor of Charles and Carol Ryan and Kristopher Jones. Ryan and Jones cross-appealed the district court's failure to rule on their claims of implied easement by prior use and easement by prescription. In 1970, Promised Land & Cattle Company conveyed a parcel of land to Timberland Resources, Inc., which included an easement to a then-existing logging road. Later that year, Timberland sold the land to Clifton with the deed containing the easement. The Ryans purchased an adjacent parcel to the Clifton property, conveyed with "all tenements, hereditaments and appurtenances thereunto belonging." The Ryans built a home on the property, accessing their parcel by a private road, access to which was via the former logging road. From 1993 until this suit was filed, the Ryans maintained the private road. Timberland conveyed another portion of its parcel to Jones, with the deed containing reference to the private road. When Clifton purchased his lot from Timberland, there was no public road providing access to what later became the Jones property, and the only access to the Jones property was the private road. Machado filed a complaint to quiet title and for declaratory relief in 2007 with regard to the easement across his property from the private road. Ryan answered and counter-claimed, asking the district court to find an easement of Machado's property by express, implied by necessity, implied by prior use and prescription. Jones was permitted to intervene. Upon review of the district court record, the Supreme Court found that the deed from Timberland to Clifton was unambiguous and did not create an express easement. The Court concluded that there existed an implied easement by necessity as to the Jones property, but to as to the Ryan property. With regard to the Ryans, the Court concluded that the Ryans could not "create" an implied easement because they sited their home in the lease accessible quadrant of their property. The Court reversed the district court with regard to finding an express easement over the Machado property and for finding an easement implied by necessity over the Machado and Clifton properties for the benefit of the Ryans. However, the Court affirmed the district court finding an easement implied by necessity for the benefit of the Jones property. The case was remanded for further proceedings on issues that were not addressed due to the court's findings on the other easement issues.
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