Latvala v. Green Enterprises Inc.
Annotate this CaseAt issue was whether a prescriptive easement existed to provide road access and utilities to a land-locked parcel and mining claim on Lake Pend Oreille in northern Idaho. Matt and Bonnie Latvala purchased the land-locked parcel, known as “Sulphide South,” in 2015 and litigation soon followed. Following a four-day bench trial and site visit, the district court quieted a prescriptive easement to the Latvalas through and over what was known as South Camp Bay Road, as well as confirming and defining an express easement across another parcel known as “Sulphide North.” Some neighboring landowners appealed the district court’s judgment, arguing the court’s findings were not supported by substantial and competent evidence. These neighbors also argued the district court erroneously allowed the prescriptive easement to be unreasonably expanded. After review, the Idaho Supreme Court affirmed the district court’s determination that the use of the road at issue by Latvala’s predecessors in interest during the active mining years (1946 to 1954) created a prescriptive easement; however, the Court reversed the district court’s judgment expanding the scope of the easement.The district court’s award of costs to Latvala as the prevailing party was vacated and the matter remanded so that the district court could consider Latvala’s remaining claims about whether South Camp Bay Road was a public road and whether he has an easement by necessity.
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