Matteson v. Batchelder
2011 ME 134
| Me. | 2011Background
- Batchelder owned land on the south side of Kenduskeag Stream; Matteson(s) owned land on the north side, upstream from a dam; historically the dam area formed a one-acre mill lot divided between sides; the 1986 deed to the Jacksons reserved a five-acre parcel and a 50-foot right-of-way along the northerly shoreline of the stream; the 1993 deed to the Mattesons reserved the same right-of-way; trial court held that Mattesons owned the northern half of the mill lot and that Batchelder had a deeded right-of-way, but found the boundary location ambiguous and later reformed the deed to follow a field road; appellate briefing addressed fee ownership and the right-of-way location; the appellate court affirmed fee ownership in Mattesons and vacated the right-of-way ruling, remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fee ownership of the northern half of the mill lot | Batchelder argues the 1986 description plus the 1936 reference limited conveyance. | Matteson asserts the 1986 deed unambiguously conveyed the northern half. | Mattesons hold the northern half of the mill lot. |
| Right-of-way boundary and Batchelder's standing | Batchelder contends he held a deeded right-of-way and possibly a five-acre parcel access. | Matteson disputes Batchelder's standing and seeks proper boundary location. | Assume Batchelder had standing; boundary to be located by ground boundary (northerly shoreline) on remand; court erred in reforming. |
Key Cases Cited
- Snyder v. Haagen, 679 A.2d 510 (Me. 1996) (deed boundary construction and use of extrinsic evidence)
- Jordan v. Shea, 2002 ME 36 (Me. 2002) (extrinsic evidence allowed when deed terms are ambiguous)
- Proctor v. Hinkley, 462 A.2d 465 (Me. 1983) (shore/bank boundary interpretation for non-tidal water bodies)
- Moulton v. Moulton, 1998 ME 31 (Me. 1998) (equitable reformation to reflect true intent of parties)
- Sabasteanski v. Pagurko, 232 A.2d 524 (Me. 1967) (deed construction and boundaries; reference to other deeds not to limit conveyance)
- Whitmore, State v. Whitmore (Me. 1988) (trial court resolution of conflicting evidence in bench trial)