Charles Martin v. Glen Wilson

Syllabus

The defendants, Glenn Wilson and Valerie Wilson, appealed from a Superior Court judgment entered in favor of the plaintiffs, Charles Martin and Nicole Martin. The plaintiffs prevailed on their claim for injunctive relief, allowing them access to a common driveway for the purpose of entering and exiting their property and enjoining the defendants from interfering with such use. Conversely, the defendants' counterclaims for trespass and injunctive relief were dismissed by the trial justice. On appeal, the defendants contended that the trial justice erred by (1) allowing parol evidence to be admitted (2) finding an implied easement over the common driveway and (3) finding that the defendants' counterclaims were moot. The Supreme Court first held that the trial justice properly considered extrinsic evidence, beyond the deed, to determine whether an implied easement existed in view of the nature of implied easements. The Supreme Court then held that the surrounding circumstances demonstrated continuous and apparent use of the common driveway prior to severance of the property and that such use was reasonably necessary. Thus, the Supreme Court held that the trial justice appropriately concluded that an implied easement existed. Finally, the Supreme Court held that, because an implied easement existed, the defendants' claims were moot. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.