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City of Pasadena v. Califoria-Michigan Land & Water Co.

    Brief Fact Summary.

    The Supreme Court of California ruled that a beneficiary of an easement cannot exclude other separate easement beneficiaries when there is no specific language as to the exclusiveness the beneficiary possesses regarding the easement in the deed. 

    Synopsis of Rule of Law.

    Unless the deed specifies clear exclusive language indicating the beneficiary is the only beneficiary of the easement, the easement beneficiary cannot exclude others from using the area within the easement. 

    Facts.

    The City of Pasadena (Plaintiff) possesses several easements throughout the city across various pieces of land. The easements relevant to the case at bar regard water lines that run throughout the city. The deed in which the Plaintiff possesses fails to specify any exclusiveness regarding the area within the easement. California-Michigan Land & Water Co. (Defendant) also received similar easements through the land pertaining to the easements the Plaintiff possesses. The city brought suit filing injunctive relief in which they sought to have the Defendant’s water lines removed. The trial court ruled in favor of the defendant and the Plaintiff appeals.

    Issue.

    Whether an easement holder can prevent access to the land pertaining to the easement, if the deed fails to specify any exclusiveness to the beneficiary of the easement? 

    Held.

    No. The Court ruled that the deed must contain exclusive language in order for the beneficiary of the easement to forbid others from accessing the land. The servient estate may convey as many easements as they desire so long as the new easements do not interfere with the original or any preceding easement holder’s use. Furthermore, the Court notes that there must be clear and convincing evidence that there is an exclusive element within the deed. The Court affirms the trial court’s ruling. 

    Discussion.

    The Court notes that the servient estate providing the easement may provide as many easements as it desires so long as it does not interfere with the easement beneficiary’s use of the easement. 


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