Clement v. Shea

CourtSuperior Court of Maine
DecidedFebruary 12, 2004
DocketHANre-00-21
StatusUnpublished

This text of Clement v. Shea (Clement v. Shea) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clement v. Shea, (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE SUPERIOR COURT HANCOCK, SS. CIVIL ACTION Docket No. RE-00-21

x : if

Howard W. Clement et al.,

Plaintiffs Vv. Findings and Decision CO AALD £ Arno B. Shea, Jr. et al., be aye Defendants

APR +3 p04

Hearing in this matter was held on August 18 and 19, 2003. Counsel for the plaintiffs was present along with some, but not all, of the plaintiffs themselves. Counsel for the defendants was present with defendants Cynthia Thibodeau and Phyllis Thle. Defendant Arno Shea had died prior to the trial. Counsel for the defendants indicated that because his interest in the case had been conveyed to or had devolved to the remaining two defendants, no action was needed under M.R.Civ.P. 25(a), and that all matters involved in this case could be fully litigated and resolved without such action. Following the trial, the parties submitted written argument, which the court has considered.

At issue in this case is whether the plaintiffs have an easement by prescription over the land owned jointly by the surviving defendants, which consists of a road that has been in existence for nearly fifty years and which they use to gain access to their parcels of real estate located on or near the shore of Green Lake in Ellsworth.

A prescriptive easement is established upon proof of (1) continuous use of the servient estate (2) for at least twenty years, (3) under a claim of right adverse to the owner of the servient estate, and (4) with either the knowledge and acquiescence of the owner of the servient estate or a use so open, notorious, visible and uninterrupted that

knowledge and acquiescence will be presumed. Eaton v. Town of Wells, 2000 ME 176, q 32, 760 A.2d 232, 244. As proponents of the putative easement, the plaintiffs bear the burden of proving these elements by a preponderance of the evidence. See Glidden v. Belden, 684 A.2d 1306, 1317 (Me. 1996).

The road at issue here crosses the easterly end of the defendants’ land and runs in roughly a north-south direction. It begins at the southeast corner of that parcel where it branches off from another road that runs in a westerly direction toward the lake and ends at the defendants’ camp. See generally defendants’ exhibit 2 (survey). The road at issue in this case was constructed in the mid-1950’s, when the owners of several parcels located on the shore north of the defendants’ property wanted a better means of access to those lots than the road that was then in existence (the Wormwood Road, connecting to Evergreen Way). Those lots are in the immediate area of what appears on defendant’s exhibit 2 to be a stream. At that time, the defendants’ property was owned by Arno Shea, who was the father of the two surviving defendants. The owners of the lots located to the north of Arno Shea’s included Arno’s brother, John Shea, and his brother-in-law, Leslie Stratton. Arno had constructed a road to his camp in the early 1950’s, and he allowed John Shea, Leslie Stratton and one George Gillis to build the road that is in dispute here. Arno himself participated in the work. At the time the road was constructed, there were several camps on parcels now owned by some of the plaintiffs. Those landowners also worked on the road or made financial contributions used to subsidize its construction and maintenance. In 1955, John Shea, Stratton and Gillis formed a road association that was responsible for maintaining the road. All of this was done pursuant the arrangements made with Arno, under which he would permit them to build and use the road so long as the road association would remain responsible for its upkeep. Arno remained centrally involved in the road committee, serving, for example, as its chair in 1958. See defendants’ exhibit 3. Arno also maintained records of payments made to the committee and the amounts disbursed from those receipts for materials used to maintain the road. See id.

The roadwork became something of a community and social project. The local lot owners who used the road knew each other, and they would routinely spend time clearing brush, filling in depressions and do other similar work. Children from those

families would appear and be allowed to drive some of the equipment. Over time, more camps were built on lots near the access provided by the road that traversed over Arno’s land. Not all of those landowners expressly sought Arno’s permission to use the road. However, as John Shea, Jr. testified, in order to be able to use that road, the owners of those lots either worked on the road or made financial contributions toward its upkeep, thus perpetuating the original arrangements. Up to the present time, there exists a group or committee that is responsible for road maintenance. Aro was occasionally approached by people who wanted to secure a deeded right of access using the road. However, Arno consistently refused those requests. In approximately 1981, one of the lot owners asked Arno to allow s power utility to run power lines across his (Amo’s) land in the approximate location of the road. Ammo refused because it would require a formal right-of-way, which he was unwilling to grant. Power lines ultimately were run to the lakefront parcels, but those lines largely circumvented Amo’s land.

Due to increasing traffic on the road, particularly during the winter when, without Arno’s permission, some lot owners sometimes plowed the road, in November 1995 Amo caused a notice to be posted at six locations along the length of the road that passed over his property. The contents of the notice satisfied the requirements of 14 M.R.S.A. § 812. Further, the certificate attached to the copy of the notice admitted into evidence conclusively establishes, under the terms of section 812, that it was posted in a way that satisfied the statutory notice requirements. This posting has the effect of fixing the prescriptive rights of the plaintiffs as of November 1995, because section 812 provides that upon such posting, claimants of a prescriptive easement cannot obtain prescriptive rights thereafter. Then, in 1999, Arno posted a sign expressing his intention to close the road. The erection of that sign led to this lawsuit, in which the plaintiffs claim that they have prescriptive rights to use the road and that Arno is no authorized to close the road or otherwise interfere with their rights.

The defendants argue that the permission granted by Arno Shea for the nearby landowners to use the road was a personal right. In effect, the defendants argue that any rights to use the property consisted of an easement in gross, rather than an easement appurtenant. “An easement appurtenant is created to benefit the dominant tenement and

runs with the land.” O’Donovan v. McIntosh, 1999 ME 71,77, 728 A.2d 681, 683; see also O'Neill v. Williams, 527 A.2d 322, 323 (Me. 1987). An easement that “does not profess to create a benefit in favor of any land” is regarded as an easement in gross. ALC Development Corp. v. Walker, 2002 ME 11, q 14, 787 A.2d 70, 775. Easements appurtenant are more favored than easements in gross, and “[w]henever possible an easement should be fairly construed to be appurtenant to the land of the person for whose use the easement is created.” Id;; Stickney v. City of Saco, 2001 ME 69, { 33, 770 A.2d 592, 605; O’Neill, 527 A.2d at 323. Here, the best evidence reveals that the purpose of the easement was to provide access to the lots as an alternative to the Wormwood Road. Further, the succession of lot owners who were able to benefit from the use of the road located on the defendants’ property is at least as suggestive as an easement appurtenant as one in gross.

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Related

O'Donovan v. McIntosh
1999 ME 71 (Supreme Judicial Court of Maine, 1999)
Gutcheon v. Becton
585 A.2d 818 (Supreme Judicial Court of Maine, 1991)
Eaton v. Town of Wells
2000 ME 176 (Supreme Judicial Court of Maine, 2000)
O'NEILL v. Williams
527 A.2d 322 (Supreme Judicial Court of Maine, 1987)
Taylor v. Nutter
687 A.2d 632 (Supreme Judicial Court of Maine, 1996)
Glidden v. Belden
684 A.2d 1306 (Supreme Judicial Court of Maine, 1996)
ALC Development Corp. v. Walker
2002 ME 11 (Supreme Judicial Court of Maine, 2002)
Stickney v. City of Saco
2001 ME 69 (Supreme Judicial Court of Maine, 2001)

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Bluebook (online)
Clement v. Shea, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clement-v-shea-mesuperct-2004.