Charles Martin et al. v. Glen Wilson et al.

Summary

The Rhode Island Supreme Court reviewed a dispute between adjacent property owners concerning use of a common driveway and alleged right-of-way easement. The Court held that the trial justice properly considered extrinsic evidence to determine whether an implied easement existed and affirmed the injunction permitting the plaintiffs to use the disputed portion of the driveway. The Court also upheld dismissal of the defendants’ related counterclaims as moot.

Holdings

1. Although the deeds were clear and unambiguous and did not create an express easement, the trial justice properly considered testimony, maps, and other extrinsic evidence to determine whether an implied easement existed.
2. The Martins established by clear and convincing evidence an implied easement over the disputed portion of the common driveway.
3. The Wilsons' claims for declaratory judgment, trespass, and equitable relief were moot because the court upheld the existence of the implied easement.

Questions Presented

1. Whether the trial justice improperly admitted extrinsic evidence concerning the circumstances surrounding the deeds when determining whether an implied easement existed.
2. Whether clear and convincing evidence established a continuous and apparent use of the disputed common-driveway area before severance and that the easement was reasonably necessary for the convenient and comfortable enjoyment of the Martins' property.
3. Whether the Wilsons' counterclaims and related claims were moot once the court determined that an implied easement existed.

Disposition

affirmed