Baker v. Pike

Summary

The Supreme Court of Wyoming held that language in 1904 deeds created a perpetual easement appurtenant for a ten-foot alley, rather than a revocable license. The court concluded that the easement benefited the owners of the affected parcels, ran with the land through subsequent transfers, and supported the Pike Family Trust's ingress and egress. The court affirmed the district court's order enforcing the easement.

Holdings

1. The 1904 deeds created an easement appurtenant over the ten-foot alley, not a revocable license.
2. The appurtenant easement transferred with the dominant property and survived later conveyances even when subsequent deeds did not expressly mention it.
3. The scope of the easement was not limited to the uses contemplated at the time of its creation; Pike's current use for ingress and egress to the rear of the property was reasonable.

Questions Presented

1. Whether the 1904 deeds created an easement appurtenant rather than merely a license.
2. Whether the easement survived subsequent transfers of the properties despite not being repeated in every later deed.
3. Whether the scope of the easement was limited to the uses contemplated when it was created.

Disposition

affirmed