Christensen v. City of Pocatello
Supreme Court of Idaho
292 P.3d 264 (Idaho 2012)
A private roadway and utility easement was created solely to give the owner of a parcel called Sewer Lagoon access across an adjoining property; the City of Pocatello (defendant), which later acquired both Sewer Lagoon and the easement, sought to connect that easement and an adjacent unopened public road to its citywide bike path and greenway system, effectively turning the private access easement into a public through-route. Neighboring landowners the Christensens and Fairchilds (plaintiffs) sued to enjoin this plan, arguing it exceeded the easement's intended scope; the lower court ruled for the city, and the Christensens appealed.
Whether a private easement created to provide access to a specific dominant parcel may be used to benefit other properties beyond that dominant estate, such as by connecting it into a broader public thoroughfare.