Springer v. Cahoy

Plaintiffs, who owned a landlocked parcel of land, brought suit against Defendant, claiming they had an implied easement over Defendant's land. The circuit court granted judgment for Plaintiffs, concluding that an easement implied from prior use existed. The Supreme Court reversed. On remand, Plaintiffs argued for a common law implied easement by necessity. The circuit court found three separate grounds that prevented Plaintiffs from being entitled to an implied easement by necessity: (1) the requirements for an implied easement by necessity were not met, (2) an adequate remedy at law barred equitable relief, and (3) South Dakota's Marketable Title Act (SDMTA) barred the action because the severance occurred outside SDMTA's twenty-two year provision. The Supreme Court affirmed on the ground that SDMTA barred Plaintiffs' action.View "Springer v. Cahoy" on Justia Law