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Lago v. Guerrette

Citations: 219 Conn. 262; 592 A.2d 939; 1991 Conn. LEXIS 293Docket: 14220

Court: Supreme Court of Connecticut; June 18, 1991; Connecticut; State Supreme Court

Narrative Opinion Summary

This case involves an action to quiet title concerning an easement claimed by the plaintiff over the defendants’ property on Janet Avenue. The trial court found that the plaintiff holds an easement by deed for the right of way, a decision subsequently appealed by the defendants. The central issue on appeal was the extent of the easement, whether it permitted traversal south to Janet Avenue or was limited to northward travel. Historically, the land was part of a larger tract owned by Ina M. MacLeod, with various parcels sold over time, some with easements. The plaintiff acquired his parcel from Joseph Brilsky, which explicitly granted a right of way over Janet Lane, also known as Old Wood Road. The trial court concluded, based on deed language and property circumstances, that the easement allowed southward travel, a conclusion affirmed by the appellate court. The appellate court underscored that ambiguities in easement instruments should favor the grantee and are determined by the express language of the deed rather than the parties' subjective intent. The judgment in favor of the plaintiff was affirmed, allowing the easement's use as claimed.

Legal Issues Addressed

Ambiguities in Easement Instruments

Application: The court emphasized that any ambiguities in the language of easement instruments should be interpreted in favor of the grantee.

Reasoning: The court emphasized that ambiguities in easement instruments favor the grantee and that interpretations of reservations are based on expressed intent in the deed.

Easements by Deed

Application: The appellate court upheld the trial court’s finding that the plaintiff holds an easement by deed allowing traversal over the defendants’ property.

Reasoning: The trial court determined that the plaintiff holds an easement by deed for the disputed right of way, which is now under appeal.

Interpretation of Easement Scope

Application: Determination of an easement's scope is based on the deed’s language, the property situation, and surrounding circumstances, not the parties' actual intent.

Reasoning: The court disagreed, stating that the determination of an easement's character and extent is based on the deed's language, property situation, and surrounding circumstances, rather than the parties' actual intent.