Farnsworth v. Meadowland Ranches, Inc.

Quiet title was properly granted to Plaintiff because Defendant failed to prove the existence of the easement on the merits. Defendant's strongest argument was denied because Defendant did not provide enough evidence to show, "Meadowland engaged in “open and known” acts of public dedication... that would give rise to an implied dedication."

Defendants made a declaratory judgment counterclaim on the existence of an easement allowing them to circumvent a failure to preserve judgment as a matter of law on the quiet title claim.  Defendant assigned error to the trial court for granting Plaintiff quiet title and the exclusive right to use a gravel road on their property. The existence of the easement was decided on the merits. Defendant argued there was express easement for the public, third-party beneficiary of the deeds, implied public easement, and implied dedication of a public road. The court reviewed each argument in part. The express easement for the public was in fact granted expressly to Meadowland Ranches, in gross. For this reason the court also rejected the third-party beneficiary argument. Defendant's did not address the factors to prove an implied easement. Lastly, the "open and known" element of public dedication could not be proven with the existence of one unrecorded map. The Court held that the trial court did not err in quieting title in the Plaintiff’s favor because Defendant failed to prove the existence of an easement. Affirmed.