Randall v. Wooddell, 51549

This case concerns a property dispute over the use of the unpaved portion of Hawk Haven Avenue between neighbors, the Randalls (plaintiffs) and Wooddell (defendant), in Ada County, Idaho.
The Randalls and their property’s prior owners used the disputed roadway and land for access to a barn, corral, arena, and pasture since at least 1996.
In 2019, Wooddell purchased a quitclaim deed for the disputed land from the original developer (Development West) and subsequently sought to exclude the Randalls' access, leading to escalating conflicts.
The Randalls sued for a declaratory judgment that their access to Hawk Haven Avenue was protected by a prescriptive easement; Wooddell counterclaimed to quiet title and alleged trespass.
After a bench trial, the district court found the Randalls had established a prescriptive easement and awarded them costs; it also dismissed Wooddell’s trespass claim.
Wooddell appealed, challenging both the finding of a prescriptive easement and the award of costs; the Court of Appeals affirmed the trial court’s judgment.

Issue	Randall's Argument	Wooddell's Argument	Held
Prescriptive Easement Established?	Use was open, notorious, continuous, adverse, for statutory period	No substantial evidence of required use elements	Randalls proved all elements; easement valid
Open and Notorious Use	Prior owners’ and Randalls’ use visible and obvious	Use was not open/prior owners believed use was permissive	Use was open/notorious, evidence sufficient
Continuous and Uninterrupted Use	Use by Randalls and predecessors unchanged since 1996	Lack of maintenance/parking not sufficient for continuity	Evidence supports continuous use
Adverse Use Under Claim of Right	Use was adverse by fencing/barn/location, not owners’ mindset	Prior owners thought use was not adverse	Nature of use was adverse; owners’ belief irrelevant
Statutory Period Satisfied	Use dates back to 1996, tacking applies, 5-year rule met	No use before 2019 established, so not enough time	Statutory period satisfied by tacking
Costs to Prevailing Party	Randalls prevailed on main claim, entitled to costs	Costs improper due to lack of easement	Costs properly awarded to Randalls
Attorney Fees on Appeal	Appeal was unreasonable/frivolous	Wooddell should receive fees as prevailing party	Attorney fees awarded to Randalls

Latvala v. Green Enters., Inc., 168 Idaho 686 (Idaho 2021) (sets out elements for prescriptive easement in Idaho)
Hodgins v. Sales, 139 Idaho 225 (Idaho 2003) (discusses tacking and prescriptive easement requirements)
Backman v. Lawrence, 147 Idaho 390 (Idaho 2009) (presumption of adversity and burdens of proof in prescriptive easement claims)
H.F.L.P., LLC v. City of Twin Falls, 157 Idaho 672 (Idaho 2014) (Idaho’s disfavor of prescriptive easements)