McDonald's USA, LLC v. Craft
2017 WL 818241
D.D.C.2017Background
- McDonald’s Real Estate Company owns the parcel with the restaurant; McDonald’s USA, LLC is co-plaintiff. A single water line originating on Craft’s (defendant’s) land services both properties.
- Plaintiffs allege they subdivided land, sold the servient parcel to Craft, but retained use of the shared water line; loss of access would force the restaurant to close.
- Craft threatened to shut off water, asserting Plaintiffs owed him for water billed to him, prompting Plaintiffs to sue for injunctive and declaratory relief.
- The court granted a temporary restraining order and later a preliminary injunction preventing Craft from cutting off water pending resolution.
- Craft moved to dismiss under Rule 12(b)(6), arguing (a) no implied easement/reservation because he didn’t know of the shared line when he purchased, and (b) no prescriptive easement because Plaintiffs had said they would install their own meter.
- The court considered only the Complaint’s allegations (declining extrinsic documents), and evaluated whether Plaintiffs plausibly pleaded an implied reservation of easement necessary to their dominant estate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Complaint plausibly alleges an implied reservation of an easement in the shared water line | Plaintiffs allege they subdivided land, sold servient parcel but retained use of the single water line; access is necessary to operate the restaurant | Craft contends no implied easement because he was unaware of the shared line when he bought the property | Court: Complaint plausibly alleges an implied reservation; survives 12(b)(6) because alleged necessity and reservation are facially sufficient |
| Whether dismissal is appropriate where defendant disputes factual allegations and attaches extrinsic documents | Plaintiffs rely on their pleadings and factual allegations; seek declaratory relief | Craft relies on outside documents and disputed facts to negate Plaintiffs’ claim | Court: Dismissal inappropriate at this stage; factual disputes and attached documents are for later summary judgment; court declines to consider extrinsic documents not integral to the complaint |
Key Cases Cited
- Hettinga v. United States, 677 F.3d 471 (D.C. Cir. 2012) (standard for accepting factual allegations on a motion to dismiss)
- Schuler v. United States, 617 F.2d 605 (D.C. Cir. 1979) (construing complaint in plaintiff’s favor)
- Papasan v. Allain, 478 U.S. 265 (1986) (courts need not accept legal conclusions framed as factual allegations)
- Kowal v. MCI Communications Corp., 16 F.3d 1271 (D.C. Cir. 1994) (rejecting inferences unsupported by complaint facts)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for complaints)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim for relief)
- Martin v. Bicknell, 99 A.3d 705 (D.C. 2014) (implied reservation of easement requires strict necessity)
- Am. Chemistry Council, Inc. v. U.S. Dep’t of Health & Human Servs., 922 F. Supp. 2d 56 (D.D.C. 2013) (granting dismissal where complaint fails to state a claim)
- Ward v. 768 F. Supp. 2d 119 (D.D.C.) (documents outside complaint not considered unless complaint necessarily relies on them)