L. Drennan Parks v. James Steven Hendersona and Marilee Henderson, as Co-Trustees of the Henderson Revocable Trust

2026 Ark. App. 45
CourtCourt of Appeals of Arkansas
DecidedJanuary 21, 2026
StatusPublished

This text of 2026 Ark. App. 45 (L. Drennan Parks v. James Steven Hendersona and Marilee Henderson, as Co-Trustees of the Henderson Revocable Trust) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
L. Drennan Parks v. James Steven Hendersona and Marilee Henderson, as Co-Trustees of the Henderson Revocable Trust, 2026 Ark. App. 45 (Ark. Ct. App. 2026).

Opinion

Cite as 2026 Ark. App. 45 ARKANSAS COURT OF APPEALS DIVISION III No. CV-24-443

L. DRENNAN PARKS Opinion Delivered January 21, 2026 APPELLANT APPEAL FROM THE WASHINGTON V. COUNTY CIRCUIT COURT [NO. 72CV-21-2610] JAMES STEVEN HENDERSON AND MARILEE HENDERSON, AS CO- HONORABLE JOHN C. THREET, TRUSTEES OF THE HENDERSON JUDGE REVOCABLE TRUST APPELLEES AFFIRMED IN PART; REVERSED AND REMANDED IN PART

KENNETH S. HIXSON, Judge

This appeal arises from a property dispute between appellant Lloyd Drennan Parks

and appellees James Steven Henderson and Marilee Henderson, as co-trustees of the

Henderson Revocable Trust. The parties own adjacent property in Washington County,

and Parks unsuccessfully sued the Hendersons on his claim for establishing the width of an

easement over the Hendersons’ property and his quiet-title claim for ownership of a portion

of the Hendersons’ property based on boundary by acquiescence and adverse possession.

The trial court entered partial summary judgment in favor of the Hendersons on Parks’

easement claim based on the trial court’s finding that the claim was barred by res judicata.

At the subsequent bench trial on the quiet-title cause of action, following Parks’ case-in-chief,

the trial court granted the Hendersons’ motions to dismiss Parks’ remaining claims of

boundary by acquiescence and adverse possession. Parks now appeals from the partial summary-judgment order and the order dismissing

his remaining claims. On appeal, Parks argues that the trial court erroneously concluded

that his easement claim was barred by res judicata. Parks also argues that the trial court erred

in dismissing his claims for boundary by acquiescence and adverse possession because he

presented a prima facie case at trial on both of those claims. Because we agree that Parks’

claim for establishing the width of the easement was barred by res judicata, we affirm the

partial summary-judgment order. However, we agree with Parks’ remaining arguments, and

we reverse the dismissal of his boundary-by-acquiescence and adverse-possession claims and

remand for further proceedings on those claims.

I. Facts and Procedural History

In 1983, Parks purchased an L-shaped tract of property (similar to the shape of

Louisiana) from Bill Carpenter. At the time of the conveyance, Carpenter also owned the

property to the north and east of the right angle of the L-shaped property. In 1995,

Carpenter’s son (to whom Carpenter had conveyed the property north and east of Parks’

property) conveyed that property to the Hendersons.1

When Parks purchased his property from Bill Carpenter in 1983, he received an

easement over what later became the Henderson property. The 1983 warranty deed from

Carpenter to Parks conveyed “a right-of-way grant and easement over and across the existing

roadway” followed by a description of the easement’s location. This easement begins on the

1 In 2019, the Hendersons conveyed their property to James Steven Henderson and Marilee Henderson, as co-trustees of the Henderson Revocable Trust.

2 north/south boundary line of the parties’ property and generally runs in a northerly

direction over the Henderson property to access a county road.

In 1998, a dispute arose between Parks and Henderson concerning Parks’ use of this

easement. In December 1998, Parks filed a complaint for injunctive relief against Steve

Henderson alleging that Henderson had interfered with his use of the easement by closing

and locking the gate where the county road meets the easement and also by feeding cattle,

thereby causing the cattle to congregate on the easement right-of-way. In his complaint, Parks

asked for injunctive relief prohibiting Henderson from unreasonably interfering with Parks’

use of the easement. In January 1999, Henderson filed a counterclaim against Parks alleging

that the inclusion of the language in the 1983 warranty deed from Carpenter to Parks that

conveyed the easement was obtained through fraud or mistake without Carpenter’s

knowledge or consent, and therefore, the easement should be set aside. This prior dispute

over the easement resulted in the parties agreeing to a consent judgment entered in April

1999. The consent judgment ordered Steve Henderson to not unreasonably close or lock

the gate to the easement; ordered Henderson to not feed cattle near the easement; and

provided that Parks may improve the road on the easement and right-of-way as he sees fit,

including putting down gravel or other surfacing materials. Unfortunately, as it turns out,

the consent judgment did not otherwise define the easement, particularly the width.

The portion of the Hendersons’ property that Parks now claims through boundary by

acquiescence and adverse possession (hereinafter referred to as “the disputed property”) is

generally the strip of land between the surveyed north/south boundary line of the parties’

3 property and an old meandering fence that lies to the north of that boundary and extends

about 1700 feet eastward from the parties east/west boundary to the county road. The

distance between the surveyed north/south boundary line and the fence varies as the fence

meanders eastward and, at its maximum, measures about fifty feet in width. It is undisputed

that this fence was in existence before Parks purchased his property in 1983 from Bill

Carpenter and that part of the fence was removed by the Hendersons in 2016.

On November 19, 2021, Parks initiated this litigation when he filed a petition to

quiet title to the disputed property and to establish the scope of the easement. In this

petition, Parks alleged ownership of the disputed property between the parties’ north/south

boundary line and the old fence to the north based on his claim that the fence line was a

boundary by acquiescence.2 Parks alleged that when he bought his property from Bill

Carpenter in 1983, both he and Carpenter understood the fence to be the boundary line

between the two properties. Further, Parks alleged that after the Hendersons bought their

property in 1995, Parks and the Hendersons had the understanding and agreement that the

fence constituted the boundary line. Parks alleged that since purchasing his property in

1983, he has maintained, asserted ownership over, and otherwise acted in all respects as

owner of the disputed property up to the boundary line established by the fence. Parks

alleged further that Carpenter, and later the Hendersons, had acted as respective owners of

the property north of the fence and that the parties had acquiesced in the fence being the

2 Parks later filed an amended petition claiming this strip of property by adverse possession.

4 boundary line. Parks stated that in 2000, the Hendersons had a survey done showing that

the fence was not the “true” boundary line, but the Hendersons nevertheless did not attempt

to claim any interest in the disputed property for over a decade after the survey was

completed. Parks stated that it was not until 2016 that the Hendersons unilaterally decided

to tear down a portion of the fence, apparently based on the 2000 survey. In his petition,

Parks also alleged that the Hendersons had been hindering his use of his easement by

attempting to limit his use to the two dirt paths created by vehicles driven over the easement.

Parks claimed his easement is required to be thirty feet wide and requested a declaration

from the trial court to this effect.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ark. App. 45, Counsel Stack Legal Research, https://law.counselstack.com/opinion/l-drennan-parks-v-james-steven-hendersona-and-marilee-henderson-as-arkctapp-2026.