Stephen W. Riffle v. S. David Smith

Summary

The Maine Supreme Judicial Court affirmed a judgment awarding the Riffles a prescriptive easement over a triangular portion of the defendants’ property used for parking and access. The court declined to consider whether to adopt a friendly-neighbor exception to the presumption of adversity because the trial court had not found that such a relationship existed during the relevant period.

Holdings

1. The Superior Court's findings that the Riffles established the first and third elements of a private prescriptive easement were supported by competent evidence and were affirmed.
2. The court declined to decide whether Maine law should recognize a friendly-neighbor exception because the Superior Court made no factual finding that a friendly-neighbor relationship existed during the relevant period.

Questions Presented

1. Whether the Superior Court properly awarded the Riffles a prescriptive easement based on continuous, open, notorious, visible, and uninterrupted use for at least twenty years and the resulting presumption of adversity.
2. Whether Maine should adopt a friendly-neighbor exception to the presumption of adversity applicable to prescriptive easements.
3. Whether the Superior Court's factual findings were supported by the record.

Disposition

affirmed