Jerry Machado v. Charles L. Ryan, 280 P.3d 715

Promised Land conveyed SE ¼ SE ¼ of Section 19 to Timberland in 1970; a Road Easement across adjacent sections was recorded but not referencing Section 19.
Timberland's deed to Clifton included an easement reference; subsequent deeds to Jones and Machado noted access via private Shamrock Lane and reserved or noted easements.
Ryans purchased the SW ¼ SE ¼ SE ¼ of Section 19 in 1989 and built a home accessing via Shamrock Lane; they maintained the road for years.
Flat Creek Road crosses the Ryan property and a public road access exists, while the Jones property currently relies on Shamrock Lane for access.
Machado filed suit to quiet title and for declaratory relief; Ryans and Jones counterclaimed for express and implied easements; Jones intervened seeking an easement for Shamrock Lane.
District court found both an express easement and an easement by necessity (for Ryan and Jones), with a 14-foot primary easement and a separate snow-removal provision; issues of implied by prior use and prescription were left for remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an express easement was created	Ryans: deed language creates express easement.	Machado: no reservation or explicit grant; no express easement.	Express easement not created
Whether an easement by necessity exists for Ryan and Jones	Ryans/Jones: unity of title and necessity at severance; great present necessity for Ryan.	Machado: no necessity; road access via Flat Creek Road present for Ryan; Jones argues for necessity for Jones.	Jones: easement by necessity affirmed; Ryan: easement by necessity reversed
Width of the easement and snow-removal area	Court should recognize 14-foot width plus 15-foot snow-removal zones each side.	Width should be as evidenced by historical usage; snow-removal area not clearly established by evidence.	Easement width upheld at 14 feet; snow-removal width remanded for fact-finding
Whether easements by prior use or prescription exist and their scope	Ryans: prior use/prescription may exist; Jones: similar claims for his benefit.	Machado: need thorough consideration on remand; pre-2006 prescription period contested.	Remand to determine whether such easements exist for Ryan; prescription period limited to pre-2006 five-year window for remand
Attorney fees on appeal	Each party partly prevailing; fees not automatic.	Same as plaintiff; no prevailing party on all issues.	No attorney fees awarded on appeal

Coward v. Hadley, 150 Idaho 282 (2010) (clear-error standard for post-trial factual findings)
Mountainview Landowners Coop. Ass’n, Inc. v. Cool, 139 Idaho 770 (2004) (ambiguity governs contract interpretation; legal effect of unambiguous writings)
Akers I, 142 Idaho 293 (2005) (express easements require a writing and identify land and intent)
Capstar Radio Operating Co. v. Lawrence, 143 Idaho 704 (2007) (necessity standards for easements of prior use; ambiguity pivotal)
Latham v. Garner, 105 Idaho 854 (1983) (interpretation of deed language and extrinsic evidence limitations)
Thomas v. Madsen, 142 Idaho 635 (2006) (reasonableness balancing for necessity and access)
Conley v. Whittlesey, 133 Idaho 265 (1999) (secondary easements and limitations on burden)
Quinn v. Stone, 270 P.2d 825 (1954) (historical context on easement interpretation)