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Eis v. Meyer

Citations: 213 Conn. 29; 566 A.2d 422; 1989 Conn. LEXIS 324Docket: 13701

Court: Supreme Court of Connecticut; November 21, 1989; Connecticut; State Supreme Court

Narrative Opinion Summary

In this case, the plaintiffs sought an injunction against the defendant to prevent obstruction of their express easement following the enlargement of their property. The trial court initially ruled in favor of the plaintiffs, asserting the easement's validity despite the enlargement. However, the Appellate Court reversed this decision, emphasizing the clear termination clause linked to property modification within the easement's terms. The Supreme Court reviewed two issues: the rejection of estoppel due to the defendant's silence and the potential application of an implied covenant of good faith and fair dealing in easement agreements. The court upheld the Appellate Court's decision, affirming that the easement's explicit terms prevailed over the plaintiffs' estoppel claims, as the plaintiffs were aware of these terms at purchase. Furthermore, the court refused to extend the doctrine of good faith and fair dealing to this context, distinguishing the case from precedents where contractual discretion warranted such consideration. The ruling concluded with the defendant's right to enforce the easement's termination based on the clear stipulation, leading to the plaintiffs' loss of their claimed easement rights.

Legal Issues Addressed

Application of Estoppel in Property Law

Application: The court rejected the application of estoppel, as the plaintiffs were aware of the easement's terms at purchase, and the defendant had no duty to disclose further.

Reasoning: The Appellate Court found the trial court erred in applying estoppel since the plaintiffs were aware of the easement's terms at purchase.

Implied Covenant of Good Faith and Fair Dealing

Application: The court declined to extend the implied covenant of good faith and fair dealing to the easement, emphasizing the clarity of its terms.

Reasoning: The court disagrees, stating that even if a contractual aspect were present, the cited cases do not support the plaintiffs' position.

Silence and Duty to Disclose in Estoppel Claims

Application: Silence did not constitute estoppel as there was no duty to disclose, given the plaintiffs' knowledge of the easement terms.

Reasoning: Silence can be the basis for estoppel only if there is a duty to disclose relevant facts, which arises when one party knows something the other does not, and that silence misleads the other party, causing potential loss.

Termination of Easements upon Property Modification

Application: The court upheld the termination of the easement due to the plaintiffs' enlargement of their property, consistent with the easement's terms.

Reasoning: The court noted that the easement terminated upon the plaintiffs' home enlargement as per the deed.