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Facts

  • The Ulibarris, plaintiffs in this case, claimed easement rights to cross SJS Investments, LLC’s (SJS) property over four dirt trails, referred to as “Roads,” based on prescriptive easements, easements by estoppel, and easements by necessity. The dispute arose after SJS purchased land between the Ulibarris' Ranch Headquarters and Winter Pasture, and subsequently restricted access to the Roads. The Ulibarris operated a cattle business using these Roads for access and transportation related to their ranching activities. The properties involved were originally owned by the United States and passed into private ownership through patents issued pursuant to the Homestead Act.

Procedural History

  • District Court: The jury found that the Ulibarris have prescriptive easements over the four Roads. The district court, in a subsequent bench trial, determined the scope of use under the easements, concluding that the Ulibarris also have easements by estoppel over Roads 1 and 2, and easements by necessity over Roads 3 and 4.

Parties' Submissions

  • Plaintiffs-Appellants/Cross-Appellees (The Ulibarris): Argued that they have prescriptive easements over the four Roads based on adverse, open, notorious, continuous, and uninterrupted use, with the knowledge of the property owners. They challenged the limits placed on their use of Road 2.
  • Defendant-Appellee/Cross-Appellant (SJS Investments, LLC): Contested the sufficiency of evidence supporting the finding of a prescriptive easement for Road 1, the district court's refusal of a jury instruction on implied permission, the finding of an easement by estoppel for Roads 1 and 2, and the finding of prescriptive easements for Roads 3 and 4.

Legal Issues

  • Whether the Ulibarris' use of the Roads constituted prescriptive easements.
  • Whether the district court erred in its findings regarding easements by estoppel for Roads 1 and 2.
  • Whether the district court erred in finding prescriptive easements for Roads 3 and 4, given the existence of easements by necessity.

Disposition

  • The district court's ruling regarding the scope of the easement over Road 2 was reversed and remanded for further consideration.
  • The grant of an easement by estoppel as to Roads 1 and 2 was reversed.
  • The ruling that Roads 3 and 4 were subject to a prescriptive easement was reversed.
  • All other rulings, including that easements by necessity exist over Roads 3 and 4, were affirmed.

Reasons

  • The Court found that the district court's limitations on the use of Road 2 were not supported by substantial evidence and required further consideration. It also determined that easements by estoppel for Roads 1 and 2 were not supported due to the lack of evidence of permission from the landowner, Mr. Roybal, and that the existence of easements by necessity over Roads 3 and 4 precluded the simultaneous grant of prescriptive easements over these Roads. The Court's analysis was grounded in the principles of prescriptive easements, easements by estoppel, and easements by necessity, as well as the evidence presented regarding the use of the Roads and the historical relationship between the parties and the properties involved (paras 1-80).
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