Wiser v. Elliott

209 P.3d 337, 228 Or. App. 489, 2009 Ore. App. LEXIS 716
CourtCourt of Appeals of Oregon
DecidedMay 20, 2009
Docket0610270; A134804
StatusPublished
Cited by4 cases

This text of 209 P.3d 337 (Wiser v. Elliott) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wiser v. Elliott, 209 P.3d 337, 228 Or. App. 489, 2009 Ore. App. LEXIS 716 (Or. Ct. App. 2009).

Opinion

*491 SERCOMBE, J.

Plaintiffs brought adverse possession and prescriptive easement claims to obtain legal interests in a strip of land acquired by defendants from a railroad company. The trial court denied plaintiffs’ summary judgment motion, granted defendants’ summary judgment motion, and dismissed plaintiffs’ claims. Based on the undisputed facts in the summary judgment record, we conclude that the trial court correctly denied plaintiffs’ summary judgment motion and properly allowed defendants’ summary judgment motion on the basis that plaintiffs could not establish adverse possession of defendants’ property. However, defendants did not establish the absence of genuine issues of material fact on whether a prescriptive easement existed over that property. We therefore reverse the judgment as to the prescriptive easement claim and otherwise affirm.

The summary judgment record reveals the following undisputed facts. Plaintiffs own parcels of land that abut a strip of land. The strip of land was deeded to the Portland, Eugene, and Eastern Railroad in 1912 and 1913 in five conveyances. Three of those conveyances were deeds that clearly conveyed fee ownership of the land to the railroad. The two remaining conveyances were captioned “right of way deed” and granted property “to be used for right of way purposes.” The parties differ on whether those deeds conveyed easements or fee interests in the two properties.

All five parcels of land were later conveyed to Southern Pacific Company (railroad). The railroad used the properties for operation of a rail line, part of its West Side Branch in Benton and Lane counties. The railroad stopped using the strip of land for a rail line in 1958 and removed the tracks and ties from the parcels. In 1959, it notified state taxing authorities that the Interstate Commerce Commission had “authorized the abandonment of operation” of a portion of the West Side Branch that included the disputed properties and that the “strip of right of way” was “no longer needed for operating purposes.” The railroad asked that the “property be reclassified to non-operating property.” Sometime later, part of the properties began to be used as a public roadway by farmers and other residents in the area.

*492 Plaintiffs acquired interests in their adjacent properties under a 1977 land sale contract and 1995 warranty deed from the Kaysers, who had acquired the properties in 1974. Both the 1977 land sale contract and the 1995 deed from the Kaysers excepted the railroad properties from the description of the land conveyed to plaintiffs. Plaintiffs presented evidence that they and the Kaysers had used the railroad properties since 1974 “for cattle ranching, farming, and other uses for which such land is typically used” and “[u]sed the right of way as if it was their own.”

However, in 1985, plaintiffs and the Kaysers sold some of the land abutting the railroad properties to Holiday Tree Farms (Holiday). That conveyance did not include any interest in the railroad properties. Those parties also signed an easement agreement at that time. The agreement recited that the properties at issue were “land owned by Southern Pacific Railway” and that the Southern Pacific Railway properties were being used by plaintiffs to move cattle. The agreement provided for reciprocal easements to Holiday and plaintiffs “in the event Southern Pacific Railway restricts access to the land being purchased” by Holiday or “[i]n the event Southern Pacific Railway restricts the access of [plaintiffs] to move their cattle.”

Defendants acquired the strip of land at issue from the railroad by a quitclaim deed in 2005. Shortly thereafter, they demanded that plaintiffs stop using the properties. Plaintiffs then brought this action for adverse possession of three of the five parcels: Tax Lots 200, 1900, and 300. Those three properties constitute the lower portion of the strip of land. Tax Lot 200 was conveyed to defendants’ predecessor by one of the two “right of way” deeds; Tax Lots 1900 and 300 were conveyed by fee deeds. Plaintiffs’ second claim for relief was for ejectment of defendants from those same parcels because plaintiffs were “the owners in fee simple of the disputed area through adverse possession and are entitled to possession of the disputed area.” 1 Plaintiffs’ complaint also *493 included a third claim for a prescriptive easement over the roadway that follows the former path of the railroad tracks on all five parcels of land. Defendants counterclaimed for trespass damages, ejectment, and to quiet title to the parcels.

Plaintiffs moved for partial summary judgment on the basis that defendants have no legal interest in the two “right of way” parcels as a matter of law. Plaintiffs contended that the railroad abandoned its interests in those parcels and that legal title reverted to plaintiffs by that abandonment. Plaintiffs sought to establish abandonment in order to advance part of their claims for adverse possession and ejectment. Defendants moved for summary judgment and dismissal of all of plaintiffs’ claims that were asserted in the complaint. The trial court denied plaintiffs’ motion and entered a limited judgment that granted defendants’ motion and dismissed plaintiffs’ claims. Plaintiffs appeal from the limited judgment dismissing their claims with prejudice. 2

Plaintiffs make three assignments of error on appeal. First, they contend that the trial court erred in denying their summary judgment motion and dismissing their claim of ownership to the property described in the two “right of way” deeds. Plaintiffs reason that the two “right of way” deeds conveyed only easements and that those easements terminated when the railroad abandoned the properties in 1959. Plaintiffs claim ownership of the servient estate and title to the area of the easements without restriction. The trial court concluded that plaintiffs failed to prove that the railroad abandoned its interests in the properties.

*494 In their second assignment of error, plaintiffs contend that the trial court erred in granting defendants’ motion for summary judgment on the claim for adverse possession of the three parcels. The trial court determined that plaintiffs’ use of the properties was neither hostile under the common-law test for adverse possession nor carried out with an honest belief of actual ownership under the statutory test for adverse possession set out in ORS 105.620. Plaintiffs assert that their 1985 easement agreement, which recognized that the railroad had rights in the disputed property, did not defeat the hostility element of their adverse possession claim, but merely acknowledged that the railroad had a record interest.

Finally, in their third assignment of error, plaintiffs argue that the trial court erred in granting defendants’ summary judgment motion and dismissing plaintiffs’ claim for prescriptive easement under the same reasoning it used to dispose of the adverse possession claim.

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Cite This Page — Counsel Stack

Bluebook (online)
209 P.3d 337, 228 Or. App. 489, 2009 Ore. App. LEXIS 716, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wiser-v-elliott-orctapp-2009.