James Brian Snow Individually v. Rachel L. Martin, 2020 CA 000198

Rachel Martin's residence was served by a private underground gas pipeline that crossed beneath land later owned by the Trust; the line connected to a main line installed by the gas company.
The private line had been in place and in use for about 40 years—predating the separation of the two tracts from common ownership.
On July 9, 2017, James Brian Snow (installing a fence on the Trust property) struck the gas line; Martin paid $3,304 to repair it and lacked service until November 2017.
Martin sued in Henderson Circuit Court claiming a sub-surface easement (quasi-easement) across the Trust property; the trial court granted partial summary judgment in her favor finding a quasi-easement existed.
The Trust appealed, arguing the trial court erred (contending the underground line could not be “obvious and manifest” and that the easement was not reasonably necessary); the Court of Appeals affirmed the trial court.

Issue	Martin's Argument	Trust's Argument	Held
Whether a quasi‑easement exists across the Trust property for Martin's gas line	The line predated the severance, was used for ~40 years (obvious, continuous, permanent), and is highly beneficial/convenient to Martin's land	The exact installation date is uncertain; underground pipeline cannot be "obvious and manifest," so quasi‑easement elements not met	Court held quasi‑easement elements satisfied and affirmed summary judgment for Martin
Whether the easement was reasonably necessary (degree of necessity)	Relocating the line would be prohibitively expensive; the use is highly beneficial/necessary to Martin's property	Relocation or construction of a new line may be feasible and not unreasonably expensive (cited older case showing low relocation cost)	Court treated extent of necessity as sufficient for quasi‑easement; Trust offered no record evidence of relocation cost, so necessity requirement met
Whether genuine factual issues precluded summary judgment	Martin urged that record showed established prior use and necessity as a matter of law	Trust argued factual disputes and lack of obviousness of underground line precluded summary judgment	Court applied summary judgment standard de novo, found no material factual dispute preventing judgment, and affirmed partial summary judgment

Steelvest, Inc. v. Scansteel Service Center, Inc., 807 S.W.2d 476 (Ky. 1991) (summary judgment standard; view evidence in light most favorable to non‑movant)
Univ. of Louisville v. Sharp, 416 S.W.3d 313 (Ky. App. 2013) (appellate review of summary judgment is de novo when only legal issues remain)
Carroll v. Meredith, 59 S.W.3d 484 (Ky. App. 2001) (elements and factors for establishing a quasi‑easement by implication of law)
Cole v. Gilvin, 59 S.W.3d 468 (Ky. App. 2001) (necessity is the most important factor in quasi‑easement analysis)
Knight v. Shell, 233 S.W.2d 973 (Ky. 1950) (earlier authority on necessity and relocation cost, cited by Trust but distinguished by the court)