Laughlin, K. v. Schnur, R.
Laughlin, K. v. Schnur, R. No. 1337 WDA 2016
| Pa. Super. Ct. | Jul 25, 2017Background
- Kenneth and Joyce Laughlin own land bordering a 50-foot private right-of-way (ROW) created by express grant in 1984; their property has ~348.59 feet of frontage along the ROW.
- The ROW historically functioned as a farm lane with multiple access points along the southern boundary of the Laughlins' property; predecessors used an "alternate access" point for farm equipment and trailers.
- Neighbor Raymond Schnur erected a split-rail fence along the northern edge of the ROW, leaving only the Laughlins' driveway open but blocking the alternate access.
- The Laughlins sued for a permanent injunction to remove the fence and enjoin future obstructions, claiming the express easement grants access along the southern property line (not limited to a single point).
- Trial court found (and Superior Court affirmed) the easement is express and unambiguous, entitling the Laughlins to ingress/egress at any point along their southern line; Schnur’s fence substantially interfered with that easement and injunctive relief was appropriate.
Issues
| Issue | Laughlin's Argument | Schnur's Argument | Held |
|---|---|---|---|
| Scope of easement: whether ROW permits access at any point along southern property line or only a single reasonable point | Easement language ("along the Southerly line") grants right of ingress/egress/regress at any point along the southern line | Grant only provides reasonable ingress/egress; existing driveway satisfies purpose | Easement unambiguous and grants access at any point along southern property line where it borders the ROW; not limited to single point |
| Whether extrinsic evidence alters interpretation if easement ambiguous | Historic farm-lane use and circumstances support multi-point access | N/A (argued strict textual/limited purpose) | Even if ambiguous, surrounding circumstances and prior use support multi-point access; courts construe in favor of grantee |
| Whether fence substantially interferes with easement | Fence blocks historically used alternate access and therefore substantially interferes | Fencing is aesthetic boundary; driveway provides reasonable access so no substantial interference | Fence substantially interferes because it prevents full use of the area granted by the easement despite purpose being achievable at a single point |
| Remedy: whether injunction removing fence along entire length was overly broad | Seek removal of fence blocking alternate access and injunction against future obstructions | Argued remedy not narrowly tailored | Permanent injunctive relief was appropriate to abate a permanent substantial interference; remedy enforced easement rights |
Key Cases Cited
- Buffalo Twp. v. Jones, 813 A.2d 659 (Pa. 2002) (standard for permanent injunctions and review limited to legal error)
- Trimble Servs. v. Franchise Royalty Interstate Corp., 285 A.2d 113 (Pa. 1971) (permanent, substantial interference with an easement supports equitable injunctive relief)
- Louis W. Epstein Family P'ship v. Kmart Corp., 13 F.3d 762 (3d Cir. 1994) (servient estate cannot deny access to portions of an expressly granted easement merely because the purpose can be achieved in a smaller area)
- Brady v. Yodanza, 425 A.2d 726 (Pa. 1981) (an easement annexed to land by grant passes with the land even if not mentioned in subsequent transfers)