Yellowstone River, LLC v. Meriwether Land Fund I, LLC
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Yellowstone River, LLC (YR) commenced an action against Meriwether Land Fund and Meriwether Land Company (collectively, Meriwether), seeking a determination that it had an easement to access its property over Meriwether's adjacent property. Through summary judgment proceedings, the issue was narrowed to the sole question of whether YR had an easement by necessity. The district court ruled that an easement by necessity did not exist over Meriwether's property for the benefit of YR's property. The Supreme Court affirmed, holding (1) the district court erred in concluding that unity of title did not exist in this case, but (2) the court nevertheless reached the correct result because the easement failed for several reasons related to the history of ownership of the land and the fact that granting an easement would be against public policy.
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