Langley v. Frumer

CourtSuperior Court of Maine
DecidedApril 30, 2003
DocketSAGre-02-014
StatusUnpublished

This text of Langley v. Frumer (Langley v. Frumer) 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
Langley v. Frumer, (Me. Super. Ct. 2003).

Opinion

STATE OF MAINE SUPERIOR COURT

SAGADAHOC, ss. CIVIL ACTION DOCKET NO. RE-02014 oe “ss f é “~~ u fay age” MICHAEL LANGLEY and oO GLORIA LANGLEY Plaintiffs v. ORDER ON DEFENDANTS’ MOTION FOR

JUDGMENT ON THE PLEADINGS AND DEFENDANTS’ MOTION FOR ATTORNEY’S FEES AND COSTS BOM E Ce JOHN FRUMER and Lian : ene oy ELIZABETH BARRETT, ET AL., oe Defendants.

MAY 34 2003 Defendants’ Motion for Judgment on the Pleadings and Motion for Attorney’s

Fees and Costs are before the court. Plaintiff's filed a Motion to Amend the Complaint and a Second Amended Complaint on April 7, 2003. The motion amends the allegations in Counts II-IV and adds Counts V and VI. The Motion to Amend was

granted at hearing, without objection.

FACTUAL BACKGROUND

On April 20, 2001, Michael Langley (Langley) purchased property located on Abbagadassett Road in Bowdoinham, which is a discontinued gravel road on which the Plaintiff and his mother Gloria Langley,’ also a Plaintiff, own other parcels of land. Langley subsequently transferred the property to his sons in trust, with him serving as trustee. In his capacity as trustee for his two sons, Langley transferred the property to Defendants Frumer and Barrett on October 16, 2001, who also owned other property on Abbagadassett Road. Langley, as an individual, sold another parcel located on the

same road to a third party on August 22, 2001.

' The original Complaint named Gloria and Donald Langley as Plaintiffs for Count II (prescriptive easement). Donald is now deceased and has been deleted from the Second Amended Complaint. Donald Langley’s death was the only ground for dismissal of Count IL. Because the pleading has been amended, there is no need to further address Defendants’ arguments as to Count IT. In July of 2001, Defendants filed a “Notice to Prevent Acquisition of Prescriptive Easement.” Defendants also filed an “Easement in Gross” purporting to limit the Plaintiffs’ easement rights to personal access rights, not running with the land, not alienable, and subject to revocation for overuse. Langley alleges that he and his predecessors in title have continuously used the road for personal use and for utility poles in a manner satisfying the requirements of a prescriptive easement. In the alternative, Langley alleges an implied or quasi-easement was created when he owned parcels on both sides of the road and subsequently sold them separately.

Langley also seeks reformation of the deed conveying the land to the Defendants. Langley, a high-school graduate with a psychiatric disability, did not believe that the deed conveyed to the Defendants would impact his access and utility service rights to his other land on the opposite side of the road. Langley relied on the Defendants’ assurances, both of whom are attorneys in Massachusetts and long-time friends of the Plaintiffs, that the details would be worked out later. Furthermore, he did not understand the legal effect of “easement in gross” and “easement will go with the person,” which were used in the purchase and sale agreement negotiated, without representation, by the parties. The Defendants’ attorney drafted the deed.

Counts V (undue influence) and VI (Tortious Interference with Advantageous Relations) are new, have not yet been answered, and are not before the court on the present motion. Defendants seek Judgment on the Pleadings as to Counts | (Declaration of Prescriptive Easement), II (see supra note 1), III (Reformation of Deed), and IV (Implied/Quasi-easement). Defendants also seek immediate payment of attorney’s fees and costs for the alleged breach of warranty.

DISCUSSION

A motion for judgment on the pleadings is the functional equivalent of a motion

to dismiss for failure to state a claim. Monopoly, Inc. v. Aldrich, 683 A.2d 506, 510 (Me.1996); 1 Field, McKusick & Wroth, Maine Civil Practice § 12.14 at 253 (2d ed. 1970).

In reviewing a dismissal motion, the court assumes all factual allegations in the

complaint are true, Monopoly, Inc. v. Aldrich, 683 A.2d at 510 (Me.1996), and views the

complaint in the light most favorable to the plaintiffs to determine whether it alleges the elements of a cause of action or facts entitling plaintiffs to relief pursuant to some

legal theory. Id.; New Orleans Tanker Corp. v. Dep’t of Transp., 1999 ME 67, { 3, 728

A.2d at 674-75. The court may grant dismissal only when it appears beyond doubt that plaintiffs are entitled to no relief under any set of facts that may be proved in support of

their claim. Monopoly, Inc. v. Aldrich, 683 A.2d at 510 (Me.1996).

1. Standing of Michael Langley

The standing of Michael Langley is a threshold issue that must be addressed prior to consideration of the substantive attacks on his claims. As alleged in the Complaint, Langley transferred two parcels by warranty deed, one to his sons in trust and one to a third party, for which he may be individually liable if the transferees are

_not able to enjoy the easements that he conveyed in those transfers. This is sufficient to grant Langley standing as an individual.

2. Prescriptive Easement Claim

Defendants contend that Count II contains only “perfunctory allegations” of prior use of the easement and does not allege facts sufficient to support a claim of a prescriptive easement. “Acquisition of title by adverse possession requires possession for a 20-year period that is actual, open, visible, notorious, hostile, under a claim of

right, continuous, and exclusive.” Dowley v. Morency, 1999 ME 137, { 19, 737 A.2d 1061

(citations omitted). See also Stickney v. City of Saco, 2001 ME 69, T 16, 770 A.2d 592

(same requirements for a public way by prescription). Langley alleged

For more than twenty years, [he] and his predecessors-in-title have continuously used Abbagadassett Road over what Defendants Frumer and Barrett claim to be their land for ingress to and egress from the Plaintiff's property, and for utility service, under claim of right adverse to the true owners, with their knowledge and acquiescence, or used it so openly, notoriously, and visibly, without interruption, that knowledge

and acquiescence may be presumed. Second Amended Compl. { 19 (unchanged from the [First] Amended Complaint). Taking the allegations as true and in a light most favorable to the Plaintiffs, the Defendants’ Motion for Judgment as to Count I is DENIED because the Complaint

adequately states a claim for a prescriptive easement.

3. Reformation of Deed

Defendants also contend that the Plaintiffs have failed to allege a mutual mistake, which is critical to a successful reformation claim.2 A mistake is mutual when the

mistake is "reciprocal and common to both parties, where each alike labors under the

misconception in respect to the terms of the written instrument.” Poling v. Northup,

652 A.2d 1114, 1116 (Me. 1995). Cf Lietz v. Berry, 543 A.2d 367, 368 (Me. 1988) (citing

Blue Rock Industries v. Raymond Int'], Inc., 325 A.2d 66, 77 n.7 (Me. 1974) (stating that

unilateral mistake may be ground for rescission, but not reformation of contract).

The allegations in the Second Amended Complaint do not support a claim of mutual mistake. It is clear that Langley was mistaken as to how the conveyance affected his interests in the easement. It is not alleged that Defendants operated under any such mistake.

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Related

Blue Rock Industries v. Raymond International, Inc.
325 A.2d 66 (Supreme Judicial Court of Maine, 1974)
New Orleans Tanker Corp. v. Department of Transportation
1999 ME 67 (Supreme Judicial Court of Maine, 1999)
McGeechan v. Sherwood
2000 ME 188 (Supreme Judicial Court of Maine, 2000)
Dowley v. Morency
1999 ME 137 (Supreme Judicial Court of Maine, 1999)
Lietz v. Berry
543 A.2d 367 (Supreme Judicial Court of Maine, 1988)
Monopoly, Inc. v. Aldrich
683 A.2d 506 (Supreme Judicial Court of Maine, 1996)
Poling v. Northup
652 A.2d 1114 (Supreme Judicial Court of Maine, 1995)
Sprague Corp. v. Sprague
855 F. Supp. 423 (D. Maine, 1994)
Napieralski v. Unity Church of Greater Portland
2002 ME 108 (Supreme Judicial Court of Maine, 2002)
LeMay v. Anderson
397 A.2d 984 (Supreme Judicial Court of Maine, 1979)
Stickney v. City of Saco
2001 ME 69 (Supreme Judicial Court of Maine, 2001)
Bowers v. Andrews
557 A.2d 606 (Supreme Judicial Court of Maine, 1989)
Swett v. Patrick
12 Me. 9 (Supreme Judicial Court of Maine, 1835)
Hardy v. Nelson
27 Me. 525 (Supreme Judicial Court of Maine, 1847)

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