John M. Hoch v. Rob Vance, 315 P.3d 824

Original owner Jack (Cridlebaugh) owned 90 acres and subdivided it, selling parcels to Vance (20 acres), Sweet (40 acres), and Hoch (20 acres), retaining 10 acres. Two access roads from Stagecoach Road — an upper road and a lower road — existed across the property.
Cridlebaugh’s deeds to Vance, Sweet, and Hoch contained easement language; Cridlebaugh reserved easements in the Vance and Sweet deeds, including an easement over all "roadways presently existing." The Sweet deed expressly created an easement over the upper road.
The Hoch deed referenced easements "as set forth" in the Vance deed and "as reserved" in the Sweet deed, conveying "all of his interest" subject to those easements.
The Hochs used the upper road to build their house with neighbors’ consent; thereafter the Vances blocked access, prompting the Hochs to sue for obstruction of their easement.
The district court granted partial summary judgment to the Hochs, finding the Hoch deed unambiguously conveyed Cridlebaugh’s reserved easement over the upper road to the Hochs and that the easement was appurtenant; the route and scope were later resolved at bench trial to include a section of Buckboard Lane across the Vances’ property.

Issue	Plaintiff's Argument (Hoch)	Defendant's Argument (Vance)	Held
Whether the Hoch deed unambiguously conveyed Cridlebaugh’s reserved easement over the upper road	The deed’s references to the Vance and Sweet deeds transferred whatever easement Cridlebaugh had reserved, so the upper-road easement passed to Hoch	The deed is ambiguous: differing phrasing ("roadways" vs "road", singular "easement") supports multiple interpretations, so summary judgment was improper	Deed unambiguous: referencing the Vance and Sweet deeds conveyed Cridlebaugh’s reserved access, so easement passed to Hoch
Whether the reserved easement was appurtenant (benefited the dominant estate)	Easement benefited Cridlebaugh’s ownership/use of the parcel that became Hoch’s lot, so it is appurtenant	Easement did not attach to a dominant estate and thus was not appurtenant	Easement was appurtenant because it was reserved to access Cridlebaugh’s (now Hoch’s) parcel

Machado v. Ryan, 153 Idaho 212 (court interprets deed to give effect to parties’ intent; if deed unambiguous, intent is a question of law)
Porter v. Bassett, 146 Idaho 399 (same principle on deed interpretation)
Marek v. Lawrence, 153 Idaho 50 (ambiguity exists only where deed is subject to conflicting interpretations)
Ida-Therm, LLC v. Bedrock Geothermal, LLC, 154 Idaho 6 (appellate standard for reviewing summary judgment and deed ambiguity)
Jasso v. Camas Cnty., 151 Idaho 790 (parties’ differing interpretations alone do not create ambiguity)
Neider v. Shaw, 138 Idaho 503 (deed must be read as a whole to determine ambiguity)
Hodgins v. Sales, 139 Idaho 225 (distinction between appurtenant easement and easement in gross; presumption favoring appurtenant easement)