Ammons Properties, LLC v. Andrew William Spraggins

CourtSupreme Court of Alabama
DecidedMay 19, 2023
Docket2022-0821
StatusPublished

This text of Ammons Properties, LLC v. Andrew William Spraggins (Ammons Properties, LLC v. Andrew William Spraggins) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ammons Properties, LLC v. Andrew William Spraggins, (Ala. 2023).

Opinion

Rel: May 19, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2022-2023

_________________________

SC-2022-0821 _________________________

Ammons Properties, LLC

v.

Andrew William Spraggins

Appeal from Madison Circuit Court (CV-20-901102)

MITCHELL, Justice.

Andrew William Spraggins's driveway crossed a neighboring tract

of land owned by Ammons Properties, LLC ("Ammons"). After a dispute SC-2022-0821

arose between Spraggins and Ammons, Spraggins filed a complaint

asking the Madison Circuit Court to enter a judgment declaring that he

had an easement for the portion of his driveway that crossed Ammons's

property. Ammons filed a counterclaim alleging that Spraggins was

liable for several tortious acts. Following a bench trial, the circuit court

ruled that Spraggins had an easement across Ammons's property and

denied Ammons's counterclaims. Ammons appealed. We affirm the

judgment.

Facts and Procedural History

In 1991, Billy R. Webster ("Billy") acquired 7.51 acres of land ("the

Webster property") on the west side of Bell Factory Road, a public road

in Madison County. The Webster property consisted of three contiguous

tracts: a southern tract, a middle tract, and a northern tract. Four years

later, Billy died.

In the ensuing years, Billy's estate distributed the tracts to various

members of the Webster family. Charles B. Webster ("Charles") acquired

the middle tract in 2009. He took out a loan secured by a mortgage on

the property that same year. Two years later, Charles's sons acquired

the southern and northern tracts.

2 SC-2022-0821

In 2017, Charles defaulted on the loan for the middle tract, and the

tract was sold to Spraggins at a foreclosure sale. Before purchasing the

middle tract, Spraggins inspected and obtained a survey of the entire

Webster property. The survey included a note stating: "These three

tracts all belonged to [Billy] Webster and the driveways served multiple

houses. [The middle tract] uses the drive that crosses [the northern

tract]." The driveway across the northern tract was paved; the southern

tract contained a gravel driveway that also accessed the house that sat

on the middle tract.

Two years after the foreclosure sale, Ammons purchased the

southern and northern tracts from members of the Webster family. The

sole member of Ammons, Scott Ammons ("Scott"), testified that, soon

after purchasing the land, he began clearing the southern tract for

development and placed a chain across the gravel driveway located on

the southern tract. He had the property surveyed and began

construction.

In August 2020, Spraggins filed a complaint in the Madison Circuit

Court asking the court to "establish and declare the right-of-way

easements over and across the property of the Defendant, Ammons

3 SC-2022-0821

Properties, LLC, … as being, alternatively, an easement of necessity or

an easement by implication, having existed and then utilized by parties

occupying the property of the Plaintiff." Ammons counterclaimed for

damages based on theories of trespass, private nuisance, and outrage.

After a bench trial, the circuit court entered a judgment holding that

Spraggins had "an easement for ingress and egress over and across the

property belonging to [Ammons] described as and referred to during trial

as Tract 2, being the northern most property and currently containing an

asphalt driveway." The circuit court denied "[a]ll claims not specifically

addressed" in the judgment, including Ammons's counterclaims.

Ammons filed a "Motion for Reconsideration, and to Alter, Amend, or

Vacate" the judgment, which was deemed denied because the circuit

court did not rule on it within 90 days. See Rules 59(e) and 59.1, Ala. R.

Civ. P. Ammons appealed.

Standard of Review

" ' "When a judge in a nonjury case hears oral testimony, a judgment

based on findings of fact based on that testimony will be presumed correct

and will not be disturbed on appeal except for a plain and palpable

error." ' " Kennedy v. Boles Invs., Inc., 53 So. 3d 60, 67-68 (Ala. 2010)

4 SC-2022-0821

(citations omitted). But " 'that presumption [of correctness] has no

application when the trial court is shown to have improperly applied the

law to the facts.' " Id. at 68 (citation omitted).

Analysis

Ammons raises what he says are three grounds for reversal: (1) the

circuit court did not have jurisdiction to grant an easement to Spraggins,

and, if it did, Ammons was owed compensation for the easement; (2) the

evidence at trial did not support an easement in favor of Spraggins; and

(3) the circuit court erred by declining to award damages to Ammons on

its counterclaims against Spraggins. Because Ammons does not

demonstrate reversible error on any of these grounds, we affirm.

A. The Circuit Court Had Jurisdiction and Ammons Is Not Due Compensation

Ammons first argues that the judgment of the Madison Circuit

Court is void because Spraggins did not initiate the action in the Madison

Probate Court. Ammons notes that a landowner seeking to condemn a

right-of-way over neighboring land must apply "to the probate court of

the county in which the lands over which such right-of-way is desired." §

18-3-3, Ala. Code 1975. Because § 18-3-3 does not give the circuit court

5 SC-2022-0821

jurisdiction to condemn a right-of-way over neighboring property,

Ammons argues, the circuit court's order is void.

Ammons is correct that, in the absence of an existing right-of-way

to a public road, the owner of a landlocked tract may petition the county

probate court to condemn a right-of-way across a neighboring tract.

§ 18-3-1 and § 18-3-3. But that is not the only way a landowner without

access to a public road can obtain it. Relevant here, an easement by

necessity may be implied when the owner of two tracts of land, one of

which requires the use of an existing right-of-way over the other, conveys

the tract that benefits from the right-of-way. See Burrow v. Miller, 340

So. 2d 779, 780 (Ala. 1976) (explaining that an easement can arise even

when a conveyance is "not an express conveyance of the easement in

question but the deed to the property to be served by the claimed

easement" because a landowner who conveys property " 'also conveys

whatever is necessary to its beneficial use' " (citation omitted)).

In his complaint, Spraggins asked the circuit court to "establish and

declare the right-of-way easements over and across the property of the

Defendant," either as "an easement by necessity or an easement by

implication, having existed and then utilized by parties occupying the

6 SC-2022-0821

property of the Plaintiff." Because Spraggins sought legal recognition of

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Related

Born v. Exxon Corp.
388 So. 2d 933 (Supreme Court of Alabama, 1980)
Burrow v. Miller
340 So. 2d 779 (Supreme Court of Alabama, 1976)
Rushing v. Hooper-McDonald, Inc.
300 So. 2d 94 (Supreme Court of Alabama, 1974)
Crawford v. Tucker
64 So. 2d 411 (Supreme Court of Alabama, 1952)
Cleek v. Povia
515 So. 2d 1246 (Supreme Court of Alabama, 1987)
Kennedy v. Boles Investments, Inc.
53 So. 3d 60 (Supreme Court of Alabama, 2010)
Oates v. Town of Headland
45 So. 910 (Supreme Court of Alabama, 1908)
Alabama Historical Commission v. City of Birmingham
769 So. 2d 317 (Court of Civil Appeals of Alabama, 2000)

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