Taylor v. Martha's Vineyard Land Bank Comm’n
Annotate this CaseDefendant owned and managed a nature preserve on Martha’s Vineyard compromised of parcels of land owned by Defendant. In 2010, Defendant created a hiking trail through the preserve that crossed over Plaintiffs’ property via an easement. The trail proceeded across three parcels of Defendant’s land for whose benefit the easement was created and then entered a fourth parcel owned by Defendant that was not intended to benefit from the easement. Plaintiffs filed an action to prevent Defendant from using the easement as part of the hiking trial, arguing that the bright-line rule in Murphy v. Mart Realty of Brockton, Inc. disallows any use of an easement to benefit land to which the easement is not appurtenant. On that basis, a land court judge granted partial summary judgment in favor of Plaintiffs. Defendant appealed, arguing that the bright-line rule in Murphy is overly rigid and suggested, instead, that the Court adopt a fact-intensive inquiry considering whether the use of an easement to benefit other parcels would increase unfairly the burden on the easement. The Supreme Judicial Court affirmed and thus declined to adopt Defendant’s suggestion, holding that the benefits of preserving the bright-line rule set forth in Murphy outweigh any costs associated with its rigidity.
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