Corbett v. Ruben
Supreme Court of Virginia
290 S.E.2d 847 (1982)
A company that owned two adjoining parcels recorded a 1964 declaration stating it 'created and established' a seven-car parking easement on parcel 1 for the benefit of an apartment building's owner and occupants on parcel 2, running with the title to parcel 1; parcel 1 eventually passed to Corbett (plaintiff) and parcel 2 to Ruben (defendant), and Corbett sued to quiet title, disputing whether the 1964 document validly created an easement (an earlier, invalid 1962 declaration having attempted the same thing improperly). The trial court found the 1964 document validly granted the easement, and Corbett appealed.
Whether there are specific language requirements necessary to grant an easement if the explicit grant clearly evidences the intent to grant the easement.