DeWolfe v. Agro

CourtSuperior Court of Maine
DecidedMarch 5, 2024
DocketCUMre-22-79
StatusUnpublished

This text of DeWolfe v. Agro (DeWolfe v. Agro) 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
DeWolfe v. Agro, (Me. Super. Ct. 2024).

Opinion

STATE OF MAINE SUPERIOR COURT

CUMBERLAND, ss. CIVIL ACTION DOCKET NO, 22-79 Poe SC - RE - g09.2 - 7 FRANK G DEWOLEFE ef al. v. JUDGMENT TYRONE AGRO

On February 23, the court heard a one-day bench trial on Plaintiff's Complaint. Count I of the Complaint alleges trespass. Count II alleges a declaratory judgment asking that the court declare the common boundary between the parties and requests injunctive relief. The Answer raises adverse possession, statute of limitations and “ownership and right of way.”

The court finds the following facts.

1. Defendant Tyrone Agro owns two lots, 37 and 38, depicted in a 1924 plan, “Cottage Lots” on land divided by Warren Winslow in Gray. He purchased the lots with a house in 1987 and raised a large family.

2. Agro’s land is abutted generally on two sides by property owned by Plaintiffs Frank and Serina DeWolfe. The DeWolfes acquired their property in one parcel from Josephine and Linwood Day in 2002 and another parcel from Tammy Gilman in 2003.

3. Pursuant to his deed, Agro has easement rights across the De Wolfe property. Referring to the 1924 Plan, he has “a right of way to pass and repass in common with others over a certain woods road shown at the top of said Plan... .” That road is now known as Cottage Road, The Plan does not show the road, but the road did abut the Agro property and the location of the near side of the right of way was fixed by the Agro property description.

The deed did not describe any additional rights to use the easement.

10.

11.

The DeWolfe deed acknowledges that the property is “subject to the rights of others” in Cottage Road, but also provides no further description of the easement rights.

In 1998, three individuals formed a road association for Cottage Road. It is not apparent to the court that the Road Maintenance/Easement Agreement binds any of the parties. Other than maintenance obligations, the Agreement does not change any of the rights of anyone benefited or burdened by the Cottage Road casement.

In 2007, after obtaining permission of the Road Association and the Town, the DeWolfes relocated the easement. After the DeWolfes’s attempt to relocate the easement, the easement still abuts the northerly side of the Agro property. It no longer abuts the western side. There was no evidence that Agro agreed to the relocation of the right-of-way.

Not surprisingly, the Agro’s large family explored and played on the roads and nearby woods. Family activities included parking vehicles, sledding, collecting firewood, road maintenance on the right of way, and depositing debris associated with automobile repair. Prior to 2007, or thereabout, when Agro built a brick patio and fence on the westerly side of his property, he primarily parked his vehicles out of the night-of-way and on his property adjacent to the house. From time to time the vehicles that he parked extended into or on the right-of-way.

Agro’s brick patio and fence encroach on the DeWolfe property.

The relations between the parties began to deteriorate. Agro kept a vehicle parked on the De Wolfe property and in the right of way.

DeWolfe complained that the vehicle blocked his route to the water when he towed his

boat. DeWolfe had permanently parked a car on the other side of the right-of-way to

12.

first.

prevent Agro from using that location to park. His own car parked in that section contributed to the difficulty moving his boat to and from the lake. The location of the boundary as well as Agro’s fence, brick patio and planters as depicted on a survey by David St. Clair, as revised on November 23, 2022, and marked at trial as Exhibit D-1 (“Survey”) are undisputed.

CONCLUSIONS OF LAW A. Adverse Possession

Because Agro’s primary defense was adverse possession, the court addresses the issue

To succeed on an adverse possession claim, a party must prove by a preponderance of the evidence that “possession and use of the property was (1) actual; (2) open; (3) visible; (4) notorious; (5) hostile; (6) under a claim of right; (7) continuous; (8) exclusive; and (9) for a duration exceeding the twenty-year limitations period. . . . [A]dverse possessors typically only acquire that property which they actually possessed.

Grondin v. Hanscom, 2014 ME 148, § 13, 106 A.3d 1150 (citations omitted). “As a general rule,

Maine law ‘disfavors the transfer of land by adverse possession.”” Fissmer y. Smith, 2019 ME

130, 941, 214 A.3d 1054 (quoting Siriefel v. Charles-Keyt-Leaman P’ship, 1991 ME 111, 7 13,

733 A.2d 984).

Here, the fence and brick patio encroaching onto the DeWolfe property may have met the

first eight requirements. They do not, however, meet the twenty-year requirement. The Agros’s

other activities on the land do not meet the requirements to establish adverse possession.

Maintenance of the road was incident to their easement rights and could not be considered

hostile. Although the other activities were frequent, they were not the types of activities that

stake a claim to exclusive possession of the property. Nor is the court satisfied they were

continuous for twenty years. Finally, Agro never provided evidence that would support the

court’s description of land acquired by adverse possession. Therefore, the court concludes that Agro cannot prevail on a claim of adverse possession. B. Trespass

Count I alleges trespass. The court reads the count to allege common law trespass.

One is subject to liability to another for trespass, irrespective of whether he thereby causes harm to any legally protected interest of the other, if he intentionally

¢ (a) enters land in the possession of the other, or causes a thing or a third person to do $0,0r

* (b) remains on the land, or

* (c) fails to remove from the land a thing which he is under a duty to remove.

Restatement (Second) of Torts § 158 (1965); Medeika v. Watts, 2008 ME 163, 95, 957 A.2d 980. While an easement benefitting Agro burdens the De Wolfe land, the DeWolfes still own the fee and the easement holders only have the right to carry out the activities permitted by the easement. SE & HLL. Shepherd Co. v. Shibles, 100 Me. 314, 61 A. 700, 702 (1905). Excessive use of an easement is a trespass. Morissette v. Somes, 2001 ME 152, { 10, 782 A.2d 764 (citing Reed v. A.C. McLoon & Co., 311 A.2d 548, 552 (Me.1973)).

The Complaint alleges two trespasses. First, it alleges that a fence, brick patio and landscape timbers encroach onto the DeWolfe property. Here, the location of the boundary and the encroachments as depicted on the Survey. The court finds that the fence, patio and landscaping encroach on the DeWolfe property as depicted on the Survey and are outside of Agro’s easement rights. Therefore, they constitute a trespass.

Second, the Complaint alleges that Agro’s vehicles parked on Cottage Road are a trespass. Whether the parking exceeds the scope of the Agros’s easement to use Cottage Road to “pass and repass” is a more difficult question. There is no Maine law directly on point with

respect to the parking issue. Generally, “[w{hen the purposes of an express easement are not

specifically stated, a court must ascertain the objectively manifested intention of the parties [to the original conveyance] in light of circumstances in existence recently prior to the execution of the conveyance.” Flaherty v. Muther, 2011 ME 32, 755, 17 A.3d 640 (quoting ine Line, Inc. v. Blake, 677 A.2d 1061, 1064 (Me. 1996)).

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DeWolfe v. Agro, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dewolfe-v-agro-mesuperct-2024.