Jigliotti Family Trust v. Donald Edward Bloom, Deborah Jane Bloom, and John W. Moore, 497 P.3d 472

A 1966 agreement between Henry Jones and Joseph Reid granted Jones a license to construct and use an access highway across Reid’s land; that land later passed to the Blooms and the Jones land to the Jigliotti Family Trust.
The access road (easement) runs from Willow Fishhook Road across Moore and Borough parcels, then across the Blooms’ parcel into the Trust property.
The Blooms moved onto Reid’s former parcel in 1994–97, built a house and outbuildings on or adjacent to the claimed roadway, and repeatedly confronted or restricted the Jigliotti family and others using the road.
The Trust filed a quiet-title action in 2012 after intermittent, limited use of the road by Jigliotti family members and after failed attempts to market the Trust property.
On summary judgment the superior court held the 1966 license created an easement appurtenant. After trial the court found the Trust’s claim barred by laches and alternatively that the Blooms had partially extinguished the easement by prescription (ending the easement about 25 feet from the Blooms’ house).
The Supreme Court affirmed the prescriptive extinguishment and remanded for entry of a final judgment quieting title consistent with the rulings.

Issue	Plaintiff's Argument (Trust)	Defendant's Argument (Blooms)	Held
Validity of the 1966 license / easement	License valid; creates appurtenant easement to access Trust land	License void as against public policy/homestead patents	Superior court: license valid on summary judgment; this determination stands
Laches (delay)	Delay not unreasonable; defendants did not properly plead laches	~15-year delay after Blooms’ obstructive acts caused prejudice; laches bars suit	Superior court found laches barred the claim; appellate opinion affirmed on alternate ground (prescription) without resolving whether laches was timely pleaded
Extinguishment by prescription	Blooms’ uses were permissive, intermittent, and did not permanently obstruct the road; no adverse use to start prescriptive period	Blooms openly, continuously, notoriously, and hostilely used/occupied the roadway (house, outbuildings, utilities) starting in mid‑1990s	Court did not clearly err: prescriptive extinguishment established by clear and convincing evidence; easement ended ~25 feet from Blooms’ house
Easement by necessity / relief and final judgment	Trust claimed necessity and sought declaration of route/judgment enforcing access	Blooms pointed to alternative section-line route and that Trust had not pursued required permits; opposed broad relief	Trial court dismissed necessity claim as premature; Supreme Court remanded for entry of a final, Rule 58 judgment quieting title consistent with the rulings

Reeves v. Godspeed Props., LLC, 426 P.3d 845 (Alaska 2018) (prescriptive‑easement principles and examples of non‑adverse temporary uses)
Hansen v. Davis, 220 P.3d 911 (Alaska 2009) (Alaska adopts prescriptive extinguishment standard requiring open, notorious, continuous adverse use for ten years)
Burke v. Maka, 296 P.3d 976 (Alaska 2013) (elements of laches: unreasonable delay and prejudice)
HP Ltd. P’ship v. Kenai River Airpark, LLC, 270 P.3d 719 (Alaska 2012) (standards for easement prescription and related property principles)
Peters v. Juneau‑Douglas Girl Scout Council, 519 P.2d 826 (Alaska 1974) (use that puts easement holder on notice starts prescriptive period)
Freightways Terminal Co. v. Indus. & Com. Constr., Inc., 381 P.2d 977 (Alaska 1963) (doctrine and scope of easement by necessity)
Whitesides v. State, Dep’t of Pub. Safety, Div. of Motor Vehicles, 20 P.3d 1130 (Alaska 2001) (deference to trial court credibility findings)