Ronkowski v. United States, No. 18-2269 (7th Cir. 2018)Annotate this Case
Ronkowski own 120 acres of undeveloped land in Bayfield County, Wisconsin. Since acquiring the property in 1972, Ronkowski has accessed it via an unpaved road that crosses over neighboring land, including land owned by the U.S. Forest Service. Ronkowski brought suit under the Quiet Title Act seeking recognition of an easement to access their property by way of the unpaved road. The Seventh Circuit affirmed Ronkowski had not established entitlement to an easement. Ronkowski did not make the required showing for an easement by necessity or an easement by implication because the existing forest service road provided them an alternate route by which to reach their property. Ronkowski could not demonstrate that the easement was necessary to access the property; even if traveling by way of forest road would be “inconvenient, difficult or require a high clearance vehicle,” there was no evidence that it is impossible.