Beverly A. Gravison et al. v. Calvert M. Fisher et al.

Summary

The Maine Supreme Judicial Court reviewed disputes involving deed reformation and easements affecting oceanfront and intertidal property in the Coopers Beach neighborhood of Owls Head. The court affirmed denial of the reformation claim, affirmed the rulings concerning the perimeter-path easements, and affirmed in part and vacated in part the rulings concerning beach easements.

Holdings

1. The Gravisons were not entitled to deed reformation because they failed to prove by clear and convincing evidence that the parties to the deed labored under a mutual mistake of fact.
2. The pre-record owners did not establish easements over the perimeter path because their deeds referred to the Blackinton Plan as laid out in June 1882, and they failed to prove that the perimeter path appeared on the original 1882 plan.
3. The post-record owners held easements over the perimeter path shown on the recorded Blackinton Plan, but those easements were limited to the path's boundaries and did not include a right to cross intervening land to reach the beach.
4. The perimeter-path easements were abandoned only where the Edwardses' home obstructed the path; they remained effective in the unobstructed portions.
5. All neighboring owners other than Bolan and Lawrence held deeded easements over the Edwardses' intertidal area; Bolan and Lawrence did not, because their claimed shore rights derived solely from a deed executed after Cora had conveyed the Edwardses' beach.
6. The beach easements permitted recreational activities reasonably related to bathing and boating, not unlimited recreational use.

Questions Presented

1. Whether the deed from Farber's estate to the Coastal Mountains Land Trust should be reformed based on mutual mistake to include the intertidal area.
2. Whether the source deeds of the pre-record owners created easements over the perimeter path.
3. Whether the source deeds of the post-record owners created easements over the perimeter path, and whether those easements included access to the beach.
4. Whether the perimeter-path easements were terminated by abandonment.
5. Whether the neighboring owners' deeds created easements over the Edwardses' intertidal beach area, including whether Bolan and Lawrence held such easements.
6. What activities were permitted under the neighboring owners' beach easements.

Disposition

other