Ruddy-Lamarca v. Dalton Gardens Irrigation District, 291 P.3d 437

Ruddy-Lamarca owns 5 acres in Kootenai County; district pipeline crosses her property and will be replaced with a ten-inch line.
Original four-inch pipeline installed 1954; a second four-inch line installed circa 1962; district later asserts a total width need of 30–40 feet for construction.
District holds an express easement across Ruddy-Lamarca’s property for irrigation-related works; the easement’s width is not specified in the 1911 grant.
Trial court found the district held an express and a prescriptive easement that are identical in location and width, determining a 16-foot easement, and ordered consideration of trees and drain field during maintenance.
District plans to use heavy machinery across the easement to install the larger pipeline, potentially harming two mature maples and Ruddy-Lamarca’s septic drain field; Ruddy-Lamarca proposed a narrower, less intrusive method with 16 feet total width.
This appeal challenges the width of the secondary easement and whether the district must preserve the trees and drain field; the court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What is the width of the secondary easement for the pipeline?	Ruddy-Lamarca argues the easement should be narrower to protect Trees/Drain Field.	District argues a wider, perhaps 40-foot width is justified.	Secondary easement width is sixteen feet; width limited by reasonable use and the circumstances at creation.
Must the District preserve trees and the drain field within the easement?	Ruddy-Lamarca contends the District must preserve trees and drain field.	District argues preservation is not required beyond reasonable use.	District must make every reasonable effort to preserve trees and drain field within the easement.
Should a new judge be assigned on remand?	N/A	District seeks reassignment due to trial timing, citing procedural concerns.	Court declines to address reassignment on remand; affirmance of district court forecloses this issue.

Coulsen v. Aberdeen-Springfield Canal Co., 47 Idaho 619 (1929) (easement scope defined by constructed ditch and its size/location)
Reynolds Irr. Dist. v. Sproat, 206 P.2d 774 (1948) (initial-use and scope principles for easements)
Beckstead v. Price, 190 P.3d 876 (2008) (prescriptive easement assessment and dimensions)
Machado v. Ryan, 280 P.3d 715 (2012) (secondary easement width determined by circumstances at creation)
Cometto v. Caldwell, 253 P.3d 708 (2011) (secondary easement must be reasonable and may preserve servient-property features)
Winslow v. City of Vallejo, 84 P. 191 (Cal. 1906) (construction method does not expand easement width; focus on land actually occupied)
Knudson v. Frost, 139 P. 533 (Colo. 1914) (secondary easement width should be flexible to prevent overly broad grants)