McCormick v. Lachance

CourtSuperior Court of Maine
DecidedFebruary 26, 2010
DocketCUMcv-08-557
StatusUnpublished

This text of McCormick v. Lachance (McCormick v. Lachance) 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
McCormick v. Lachance, (Me. Super. Ct. 2010).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION DOCK~T NO. CV-08~7 I \.J PJ vJ . CU 1Yl- 2/f)JC/~D/ 0 CHRISTOPHER 1. MCCORNIICK, /

Plaintiff

v. DECISION & ORDER

MICHAEL D. LACHANCE, et aI.,

Defendants.

INTRODUCTION

This matter is before the court pursuant to M. R. Civ. P. 55 and 56 on Plaintiff s

(Plaintiff or McCormick) motion for summary judgment on its complaint against

Defendant Lachances (Lachance or Lachances) and Defendant Back Lot Owners l (Back

Lot Owners), seeking a declaratory judgment concerning the location and use of an

easement to the ocean. McCormick contends that as a matter of law the trail to the ocean

was relocated when a Recorded Plan describing the "Trail to Ocean" was filed and his

deed referencing the Recorded Plan was filed.

Also before the court is Defendant Back Lot Owners' cross-motion for summary

judgment against McCormick. Defendant Lachance has joined in that cross-motion. The

Back Lot Owners also seek a declaratory judgmttnt, in pertinent parts of their

counterclaim, that the easement to the ocean has never been relocated. They also claim

common law nuisance by obstruction of the easement and trespass by unreasonable

interference with the easement.

1 Defendants Samuel S. Scott, Nancy G. Reilly, Marjorie C. Adams, Stephen B. Bergson, Sally B.

Maynard, Elizabeth Sanborn Ventre, Sara L. Maynard and William D. Maynard are collectively referred to as "the Back Lot Owners," Because the court finds the summary judgment motions to be interrelated, the

court will address the parties' arguments as a whole. The court finds the motions related

because this is not simply a case establishing initially a trail to the ocean; rather, this cas

involves an easement that crosses two separately owned servient estates and that has, at

least since, 1959 provided to the dominant estate owners a traveled path by foot and

vehicle to the sea.

In 200 I, a Dr. Crane2 divided his land into two parcels. He first sold the northerly

parcel to McCormick and then conveyed the southerly parcel to Lachance. The disputed

easement crosses over both McCormick and Lachance's property.3 This dispute was

triggered by two unilateral actions taken by McCormick in 2008, one of the servient

estate owners. He first constructed a fence and stonewall on his property that blockaded

the travel path of an easement that the Back Lot Owners had been using, in substantially

the same location, since 1959. The Back Lot Owners had used that traveled way to

access the sea not only by foot, but also by vehicle to haul small watercraft and to

transport people. McCormick also cleared an area along the southerly boundary of his

property, which he contended was the only path by which the Back Lot Owners could

legally cross his land on their way to the sea. Lachance4 has not cleared the easement

where it would fall on his land under McCormick's theory, leaving the Back Lot Owners

with no actual path to the sea wide enough to allow passage by vehicle. In order to

operate vehicles capable of hauling kayaks and other small watercraft, the Back Lot

2 In 2000, Margaret Crane conveyed 49% of her property to her husband, Dr. Lawrence Crane. Dr. Crane had a power of attorney for Mrs. Crane. PSMF -n S. Dr. and Mrs. Crane are referred to individually and collectively as Crane or Dr. Crane. 3 At the parties' request, the court took a view of this property in the fall of2009.

4 Lachance contends that environmental laws and regulations prohibit the expansion of the

easement onto his property without permitting that has not yet been obtained and that may not be obtained.

2 Owners require a traveled way that is at least 14'-wide. The width of McCormick's Trail

to Ocean is 10 feet.

McCormick asserts that, as a matter of law, Dr. Crane relocated the Back Lot

Owners' easements by (a) first, recording a plan that labels a particular area of what are

now the McCormick and Lachances parcels as a "Trail to the Ocean (Easement)" (the

Recorded Plan) and then (b) referencing the Recorded Plan in his deeds to both

McCormick and the Lachances. Therefore, he argues he was free to erect a stonewall and

a stockade fence consistent with the Recorded Plan. The Back Lot Owners respond that,

as a matter of law, the McCormick and Lachance Deeds are ambiguous as to the parties'

intent for the location of the Back Lot Owners' easements, and that extrinsic evidence

supports the conclusion that Dr. Crane did not intend to relocate the existing traveled way

by virtue of those deeds and the Recorded Plan. They further argue that Dr. Crane's

deeds to McCormick and Lachance are ambiguous because they did not expressly address

whether, how, or by whom the traveled way might be relocated following the delivery of

those deeds. McCormick responds that there is no ambiguity in his deed; therefore, the

court cannot consider parol evidence.

The Back Lot Owners, joined by Lachance, cross-move for summary judgment in

their favor on the grounds that, as a matter of law, a servient estate owner who has

reserved the unilateral right to relocate the easement may legally accomplish such a

relocation only by (a) physically creating, on the face of the earth, a new easement that

provides the same utility and function as the original easement and (b) paying the full

costs of doing so. In this case, they contend that Dr. Crane did not do this.

3 The court points out that this dispute is complicated by the fact that Dr. Crane

never constructed a replacement for the traveled way that tracks the Trail to the Ocean as

described on the Recorded Plan.

FACTUAL BACKGROUND

A. Easement "to use the traveled way as it now exists"

The parties' parcels of land were once part of a tract of land locally known as the

Blanchard Farm (the Farm). Back Lot Owners' Statement of Material Facts at ~ 1 (BLO­

SMF). The Farm extended from Route 88 to the shore of Casco Bay. BLO-SMF ~~ 3-4.

As of early 1959, the Farm was owned by Defendant Sally Blanchard Maynard's

father, Dean Blanchard, and uncle, Sidney C. Blanchard (Blanchard). BLO-SMF ~ 2. On

April 24, 1959, Blanchard divided the Farm into two parcels. BLO-SMF ~~ 3-4. First,

he conveyed to Sally Maynard and her then-husband that portion of the Farm abutting

Route 88 and containing the Blanchard family farmhouse (the Maynard Parcel). BLO­

SMF ~ 3. Contemporaneously, he sold to Margaret M. Crane the remaining 10 acres of

the Farm nearest the shore (the Crane Parcel). BLO-SMF ~ 4.

The conveyance from Blanchard to the Maynard granted Maynard an express

easement over the Crane Parcel. BLO-SMF ~ 5. That easement provides:

Also granting the right in common with Margaret M. Crane, her heirs and assigns, to use by foot or vehicle, the traveled way as it now exists from the Easterly bound of the land hereby conveyed across land conveyed this day to Margaret M. Crane to the sea. In the event said Margaret Crane her heirs or assigns re­ establishes the location of said road and path the rights hereby granted to said Maynards shall be transferred to said new location.

(the Maynard Easement). Blanchard's deed to Crane expressly subjected the

Crane Parcel to the Maynard Easement:

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