Zunino v. Rajewski

¶1

Kulik, J.

This case addresses the fundamental issue of what is necessary to create an easement. We hold that the documents here designated as “private road and utility easements” simply do not create easements because they lack the required statement of intent to transfer property. We affirm the trial court.

FACTS

¶2 Gayle Anderberg sold two parcels of property to Virgil and Julie Zabinski and three parcels to Donald Zunino. The deeds for these parcels did not create easements; but for *217each sale, Ms. Anderberg recorded a “private road and utility easement” document so that she could obtain a…