Price v. Eastham, 254 P.3d 1121

Price posted No Trespassing signs in 1998 after snowmachine use damaged his land crossing a seismic trail.
The trail across Price’s land had previously been found to create a public prescriptive easement for snowmachine use.
On remand, the superior court defined the easement’s scope, including width, permissible uses, and seasonal considerations.
The 2007 remand order broadened the scope to include non-snowmachine users, which Price challenged.
The Alaska Supreme Court ultimately held the easement is limited to snowmachine users, remanding for seasonal limits, speed, and width findings.
Grooming, marking, and clearing of the trail were affirmed as permissible improvements to the easement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of prescriptive easement includes non-snowmachine users?	Price argues non-snowmachine users cannot be included.	Easement scope could include broader uses based on trial record.	Scope limited to snowmachine users.
Was there a significant increase in snowmachine traffic?	Traffic increased significantly after remand period.	No significant increase beyond prescriptive-period use.	No clear significant increase; volume not overburdened.
Seasonal limits on easement use?	Seasonal limits should be imposed to prevent damage in thaw periods.	Seasonality not properly defined; other users require access year-round.	Remand to establish seasonal limits for snowmachines.
Easement width and related findings?	Width should reflect original prescriptive use; 8–16 feet may be insufficient.	Width appropriately determined by court; later findings sufficient.	Width findings not supported by record; remand; 8 feet likely appropriate absent further proof.
Vesting easement in a government agency under AS 09.45.052(d)?	Statute should apply to vest the easement in the state.	AS 09.45.052(d) not retroactive to this case.	No vesting by statute; statute not retroactive here.

Price v. Eastham, 128 P.3d 725 (Alaska 2006) (reaffirms scope-limiting approach to prescriptive easements; remand for specifics)
Price v. Eastham, 75 P.3d 1051 (Alaska 2003) (Price I; defines guiding principles for scope and restatement reference)
Interior Trails Pres. Coal. v. Swope, 115 P.3d 527 (Alaska 2005) (prescriptive easement requirements and scope considerations)
House v. Hager, 883 P.2d 261 (Or. App. 1994) (restatement of prescription principles and scope limits)
McGill v. Wahl, 839 P.2d 393 (Alaska 1992) (elements of prescriptive rights; openness, notoriety, adversity)