Taylor v. Martha's Vineyard Land Bank Commission
475 Mass. 682
| Mass. | 2016Background
- Martha's Vineyard Land Bank Commission (defendant) owns a preserve made of four adjacent parcels on Martha’s Vineyard; none abut the public way (Lighthouse Road).
- The plaintiffs own the Inn Property, a parcel that connects Lighthouse Road to the preserve; two preexisting easements across the Inn Property provide access from Lighthouse Road: a 40-foot “Disputed Way” (appurtenant to three southern preserve parcels) and a 20-foot way (serving the northern parcel, Diem Lot 5).
- In 2010 the defendant planned a public hiking loop that would use Disputed Way across the Inn Property, continue over the three southern parcels, then proceed onto Diem Lot 5 (not appurtenant to Disputed Way), linking to the 20-foot way.
- Plaintiffs sued in Land Court seeking to enjoin use of Disputed Way to access Diem Lot 5 and argued public use would overburden the Inn Property.
- The Land Court granted partial summary judgment forbidding use of Disputed Way to reach Diem Lot 5 (relying on the bright-line rule in Murphy), but held a factual trial on whether opening Disputed Way to the public would overload or unreasonably increase pedestrian traffic; the trial judge found public use would not overburden the easement.
- Defendant appealed the summary-judgment ruling; the Supreme Judicial Court allowed direct appellate review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May an easement appurtenant to particular parcels be used to serve an adjacent parcel to which it is not appurtenant? | Murphy rule bars using an easement to benefit non-appurtenant land. | Replace Murphy's bright-line rule with a fact-based inquiry considering actual burden. | Affirmed Murphy: owner may not use an appurtenant easement to serve other parcels. |
| Would incorporating Disputed Way into a loop that reaches Diem Lot 5 overload or improperly expand the easement? | Using Disputed Way to reach Diem Lot 5 improperly extends the easement and overloads servient land. | Physical pedestrian increase would be minimal; no overloading would occur. | Use to reach Diem Lot 5 is barred; separate factual inquiry (which the judge held in favor of defendant) concerned whether public use per se would unreasonably increase burden. |
| Should Massachusetts abandon the bright-line rule for a fact-intensive, case-by-case test? | Preserve stare decisis and certainty for servient owners; bright-line rule avoids complex litigation. | Adopt functional test weighing increased burden, intent, frequency, and reasonableness. | Declined to adopt fact-based rule; benefits of certainty and reliance on precedent outweigh flexibility. |
| Appropriate remedy when easement used to serve non-appurtenant land? | Injunction required to protect servient owner's possessory interest. | Courts should be reluctant to issue injunctions when additional burden is slight. | Injunction is appropriate; court declined to discourage injunctions even where additional damage is not large. |
Key Cases Cited
- Murphy v. Mart Realty of Brockton, Inc., 348 Mass. 675 (Mass. 1965) (establishes bright-line rule: easement appurtenant cannot be used to serve non-appurtenant land)
- McLaughlin v. Selectmen of Amherst, 422 Mass. 359 (Mass. 1996) (same limitation: absent consent, use for other land constitutes overloading)
- Marden v. Mallard Decoy Club, Inc., 361 Mass. 105 (Mass. 1972) (discusses reasonable uses of an easement over time)
- Labounty v. Vickers, 352 Mass. 337 (Mass. 1967) (extent and limits of a right of way are largely factual questions)
- Patterson v. Paul, 448 Mass. 658 (Mass. 2007) (terms and manner of easement exercise governed by creators' intent)
- Doody v. Spurr, 315 Mass. 129 (Mass. 1943) (injunction appropriate to enjoin repeated trespasses on land)
- Davenport v. Lamson, 21 Pick. 72 (Mass. 1838) (historical authority that a right of way to a particular close cannot be extended to other closes)