331 A.3d 971
R.I.2025Background
- In 1929, Carrie M. Davis was granted an express easement across Seaweed Beach, appurtenant to her property (the "Davis Heritage") in Narragansett, Rhode Island, by the owners of Seaweed Beach.
- Over time, the Davis Heritage was subdivided into several lots, including those currently owned by the plaintiffs (the McElroys) and defendants (Stephens, Anthonys, Lacroix), resulting in properties that do or do not directly abut Seaweed Beach.
- The McElroys' property no longer directly abuts Seaweed Beach but historically benefited from the 1929 express easement. In 1986, they bought their parcel from the Dareliuses, who owned both the McElroy and Stephens properties at the time.
- This dispute arose when the Stephenses blocked the McElroys' access to Seaweed Beach through the Stephens’ property. The McElroys filed to quiet title and sought declaratory and injunctive relief, while defendants countersued to quiet title in their favor.
- After summary judgment and a prior appeal, a bench trial was conducted, and judgment entered for the McElroys as to an easement over the Stephens’ property, but not over the Anthonys’ or Lacroix's properties. Defendants appealed.
Issues
| Issue | McElroy Argument | Stephens/Anthony Argument | Held |
|---|---|---|---|
| Existence of express easement | 1986 deed incorporated 1929 easement to beach | No specific grant in 1986 deed; language missing | Deed incorporated 1929 easement—exists |
| Existence of implied easement | Necessary to reach/apply 1929 easement | No unity of ownership at time of 1986 conveyance | Implied easement over Stephens’ property |
| Admissibility of purchase agreement | Relevant for context/extrinsic evidence | Admission violated parol evidence rule | Proper for implied easement; not for express |
| Consistency/amendment of the judgment | Judgment matches trial findings | Judgment inconsistent with written decision | No manifest error; denial of amendment proper |
Key Cases Cited
- Wellington Condominium Association v. Wellington Cove Condominium Association, 68 A.3d 594 (R.I. 2013) (burden of proof and deference to trial findings in easement cases)
- Hilley v. Lawrence, 972 A.2d 643 (R.I. 2009) (standards for implied easements and interpretation of deeds)
- Catalano v. Woodward, 617 A.2d 1363 (R.I. 1992) (unity of possession’s effect on easements)
- Bovi v. Murray, 601 A.2d 960 (R.I. 1992) (predicate for implied easements upon division of land)
- Martin v. Wilson, 246 A.3d 916 (R.I. 2021) (use of extrinsic evidence for implied easement analysis)